The EU has recently made certain notable EU asset freeze designations in relation to Belarus1 and Syria,2 focusing on various government officials – including President Alexander Lukashenko in Belarus.
The Belarusian and Syrian governments and their ministries are not as such designated. Transactions with non-designated State-owned entities in Belarus or Syria, for example, should therefore not be restricted under EU sanctions, unless the listed individuals are personally involved or derive a benefit from such transactions. As always, due diligence must be applied in relevant dealings to ensure that the EU asset freeze restrictions are not triggered (e.g., through ownership or control by designated persons) or circumvented.
Under the EU asset freeze, all funds and economic resources in the EU belonging to or controlled by the listed persons will be frozen. Furthermore, no funds or economic resources may be made available – directly or indirectly – to or for their benefit. In limited situations, licences may be granted that would authorise such activities. Economic resources are broadly defined to include anything that can be used to obtain funds, goods or services. Standard EU nexus principles apply in relation to the sanctions, as well as typical asset freeze exemptions. All designated individuals are also subject to an EU travel ban.
The 23 new designated individuals are listed below.
Name |
Role |
Date of listing |
Alexandr Grigorievich LUKASHENKO |
President of the Republic of Belarus |
6.11.2020 |
Viktor Aleksandrovich LUKASHENKO |
National Security Advisor to the President in Belarus, Member of the Security Council |
6.11.2020 |
Igor Petrovich SERGEENKO |
Chief of Staff of the Presidential Administration in Belarus |
6.11.2020 |
Ivan Stanislavovich TERTEL |
Chairman of Belarus State Security Committee KGB, former Chairman of the State Control Committee |
6.11.2020 |
Roman Ivanovich MELNIK |
Head of Main Directorate of Law and Order Protection and Prevention at the Belarusian Ministry of Internal Affairs |
6.11.2020 |
Ivan Danilovich NOSKEVICH |
Chairman of the Investigative Committee in Belarus |
6.11.2020 |
Alexey Aleksandrovich VOLKOV |
Former First Deputy Chairman of the Investigative Committee, currently Chairman of the State Committee for Forensic Expertise in Belarus |
6.11.2020 |
Sergei Yakovlevich AZEMSHA |
Deputy Chairman of the Investigative Committee in Belarus |
6.11.2020 |
Andrei Fyodorovich SMAL |
Deputy Chairman of the Investigative Committee in Belarus |
6.11.2020 |
Andrei Yurevich PAVLYUCHENKO |
Head of Operational-Analytical Center in Belarus |
6.11.2020 |
Igor Ivanovich BUZOVSKI |
Belarusian Deputy Minister of Information |
6.11.2020 |
Natalia Nikolayevna EISMONT |
Press Secretary of the President of Belarus |
6.11.2020 |
Sergei Yevgenevich ZUBKOV |
ALFA Unit Commander in Belarus |
6.11.2020 |
Andrei Alekseevich RAVKOV |
Former State Secretary of the Security Council in Belarus |
6.11.2020 |
Petr Petrovich MIKLASHEVICH |
Chairman of the Constitutional Court of the Republic of Belarus |
6.11.2020 |
Bassam TOU’MA/TU’MA |
Syrian Minister of oil and mineral resources |
6.11.2020 |
Hassan GHABACHE/GHOBASH/AL-GHABBASH |
Syrian Minister of Health |
6.11.2020 |
Ziyad SABBAGH |
Syrian Minister of Industry |
6.11.2020 |
Mohammad Hassan QATANA |
Syrian Minister of Agriculture and Agrarian reform |
6.11.2020 |
Ghassan ZAMEL/AL-ZAMIL/AL-ZAMEL |
Syrian Minister of Electricity |
6.11.2020 |
Mohamad Fayez BARCHA/AL-BARSHA/AL-BARASHA |
Syrian Minister of State |
6.11.2020 |
Malloul HUSSEIN/AL-HUSSEIN |
Syrian Minister of State |
6.11.2020 |
Mohammad Samir HADDAD |
Syrian Minister of State |
6.11.2020 |
1 See Council Implementing Regulation 2020/1648 of 6 November 2020 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in respect of Belarus.
2 See Council Implementing Regulation 2020/1649 of 6 November 2020 implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria.
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