Home Europe Council of the European Union Council Implementing Regulation (EU) 2024/3177 of 16 Decembe...
Date: 16-Dec-2024 Category: Not Applicable State: Union Government Country: Europe

Council Implementing Regulation (EU) 2024/3177 of 16 December 2024 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

Issued by Council of the European Union · Not Applicable

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Executive Summary & Key Takeaways

What it means

  • Council Implementing Regulation (EU) 2024/3177 amends Annex I to Regulation (EC) No 765/2006, adding 26 natural persons and 2 legal entities to the list of those subject to restrictive measures in view of the situation in Belarus and its involvement in the Russian aggression against Ukraine.

Key Changes

  • 26 new natural persons have been added to the list of sanctioned individuals. These individuals are primarily judges and officials involved in the Belarusian legal system and correctional facilities, as well as businesspersons. They are being sanctioned for their roles in the repression of civil society, human rights violations, or association with entities already under sanctions.
  • Two new legal entities, Ruzekspeditsiya LLC and Vlate Logistik LLC, have been added to the list of sanctioned entities. Ruzekspeditsiya LLC is sanctioned for its association with Bremino Group LLC and for facilitating infringements of the prohibition against circumvention of the provisions of Council Regulation (EC) No 765/2006. Vlate Logistik LLC is sanctioned for benefiting from the Lukashenka regime through its status as an 'authorised economic operator'.
  • The regulation is effective from December 16, 2024.

Impact Analysis

Impact on Stakeholders

  • The Belarusian government may face increased pressure due to the expanded sanctions regime.

Suggested Action Items

  • Monitor further developments in the EU's sanctions policy towards Belarus.

Key Entities Referenced

Vlate Logistik LLC: A Belarusian company sanctioned for benefiting from the Lukashenka regime through its status as an 'authorised economic operator'. It owns two border checkpoints on the EU-Belarus border. Bremino Group LLC: A company managing the Bremino-Orsha Special Economic Zone. It was already listed in Annex I of Council Regulation (EC) No 765/2006. OAO Belaruskali: A Belarusian state-owned company producing potash fertilizers. It has been designated by the Union since 2022. Council Regulation (EC) No 765/2006: Council Regulation concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine. This regulation forms the basis for the EU's sanctions regime against Belarus. Ruzekspeditsiya LLC: A Belarusian company sanctioned for its association with Bremino Group LLC and for facilitating infringements of the prohibition against circumvention of the provisions of Council Regulation (EC) No 765/2006. It operates from the Bremino-Orsha Special Economic Zone.
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Official Journal EN of the European Union L series 2024/3177 16.12.2024 COUNCIL IMPLEMENTING REGULATION (EU) 2024/3177 of 16 December 2024 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (1), and in particular Article 8a(1) thereof, Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy, Whereas: (1) On 18 May 2006, the Council adopted Regulation (EC) No 765/2006. (2) In view of the gravity of the situation in Belarus, 26 natural persons and 2 legal persons should be included in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex I to Regulation (EC) No 765/2006. (3) Regulation (EC) No 765/2006 should therefore be amended accordingly, HAS ADOPTED THIS REGULATION: Article 1 Annex I to Regulation (EC) No 765/2006 is amended in accordance with the Annex to this Regulation. Article 2 This Regulation shall enter into force on the date of its publication in the Official Journal of the European Union. This Regulation shall be binding in its entirety and directly applicable in all Member States. Done at Brussels, 16 December 2024. For the Council The President K. KALLAS (1) OJ L 134, 20.5.2006, p. 1. ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj 1/13ANNEX Annex I to Regulation (EC) No 765/2006 is amended as follows: (1) the following natural persons are added to the list set out in section ‘A. Natural persons referred to in Article 2(1)’: Names (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) ‘262. Vitali Viktaravich Віталій Віктаравіч Judge and chairman of the court Vitali Sinila is a Belarusian judge and chairman of the court of the 16.12.2024 SINILA СIНIЛА of the Mostovsky district of the Mostovsky district of the Grodno region. He was appointed by Aliaksandr Grodno region Lukashenka. He issued sentences against a number of citizens of Belarus Vitaliy Viktorovich Виталий Викторович who voiced their opinions against the President and the regime’s SINILO СИНИЛО DOB: 15.5.1976 authorities, e.g. Viktor Tsarikevich and Sergei Burak, for the dissent they Nationality: Belarusian expressed on social media and offline. Gender: male He is therefore responsible for the repression of civil society and democratic opposition. Personal ID: 3161180C038PB1 263. Iryna Vasieuna Iрына Васільеўна Judge and chairperson of the Iryna Pradun is a Belarusian judge and chairperson of the court of the 16.12.2024 PRADUN ПРАДУН court of the Rogachev district of Rogachev district of the Gomel region. She was appointed by Aliaksandr the Gomel Region Lukashenka. She issued sentences against a large number of citizens of Irina Vasilevna Ирина Васильевна Belarus who voiced their opinions against the President. She also issued PRADUN ПРАДУН DOB: 21.5.1974 sentences against a number of individuals for their alleged participation in Nationality: Belarusian protests and for resisting the brutality of the Belarusian law enforcement authorities, e.g. in the case against Evgeny Kokhanovsky, who according to Gender: female human rights defenders was coerced into pleading guilty to having taken part in protests. Personal ID: 4210574H035PB4 She is therefore responsible for the repression of civil society. 2/13 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj EN OJ L, 16.12.2024Names (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 264. Vadzim Ivanavich Вадзім Iванавіч Judge of the Pruzhany District Vadzim Mazol is a Belarusian judge of the Pruzhany District Court of the 16.12.2024 MAZOL МАЗОЛЬ Court of the Brest Region Brest Region. He was appointed by Aliaksandr Lukashenka. He issued sentences against a large number of citizens of Belarus who voiced their Vadim Ivanovich Вадим Иванович DOB: 13.4.1974 opinions against the President and the regime’s law enforcement MOZOL МОЗОЛЬ Nationality: Belarusian authorities, including on social media. Gender: male He is therefore responsible for the repression of civil society. Personal ID: 3130474C031PB6 265. Nina Uladzimirauna Ніна Уладзіміраўна Judge of the Brest Regional Nina Shastak is a Belarusian judge of the Brest Regional Court. She was 16.12.2024 SHASTAK ШАСТАК Court appointed by Aliaksandr Lukashenka. She issued sentences against a number of citizens of Belarus who voiced their opinions against the Nina Vladimirovna Нина Владимировна DOB: 1.5.1958 Belarusian regime’s authorities. She also considered appeals against SHESTAK ШЕСТАК Nationality: Belarusian sentences of peaceful demonstrators, confirming those sentences. Gender: female She is therefore responsible for the repression of civil society. Personal ID: 4010558C080PB9 266. Vera Viacheslavauna Вера Вячаславаўна Judge of the Brest Regional Vera Filonik is a Belarusian judge of the Brest Regional Court. She was 16.12.2024 FILONIK ФIЛОНIК Court appointed by Aliaksandr Lukashenka. She issued sentences against a large number of citizens of Belarus accused of having taken part in the protests Vera Vyacheslavovna Вера Вячеславовна DOB: 8.3.1990 against the Belarusian regime in August 2020. FILONIK ФИЛОНИК Nationality: Belarusian She is therefore responsible for the repression of civil society. Gender: female Personal ID: 4080390K014PB5 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj 3/13 OJ L, 16.12.2024 ENNames (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 267. Iryna Leanidauna Iрына Леанідаўна Judge of the Minsk Regional Iryna Maiko is a Belarusian judge of the Minsk Regional Court. She was 16.12.2024 MAIKO МАЙКО Court appointed by Aliaksandr Lukashenka. She issued sentences against citizens who voiced their opinions against the President and the regime’s Irina Leonidovna Ирина Леонидовна DOB: 25.11.1974 authorities, e.g. Roman Yankouski and Mikhail Nemtsov, for the dissent MAIKO МАЙКО Nationality: Belarusian they expressed on social media and offline. Gender: female She is therefore responsible for the repression of civil society. Personal ID: 4251174A007PB7 268. Vasili Vasilievich Васілій Васільевіч Judge of the Gomel Regional Vasily Biagun is a Belarusian judge who has served in the Gomel Regional 16.12.2024 BIAGUN БЯГУН Court Court since 2003. He was appointed by Aliaksandr Lukashenka. Biagun issued numerous rulings against opponents of the Belarusian authorities, Vasily Vasilyevich Василий Васильевич DOB: 9.12.1960 including sentences against individuals for their activity on social media. BEGUN БЕГУН POB: Kondopoga, Republic of He also issued politically motivated prison sentences against Nikita Karelia, Russia Slepenka (3 years) and Pavel Bobchenko (2 years). Nationality: Belarusian He is therefore responsible for the repression of civil society. Gender: male 269. Yauheni Anatolevich Яўгеній Анатольевіч Judge of the Brest Regional Yauheni Bregan is a Belarusian judge of the Brest Regional Court. He was 16.12.2024 BREGAN БРЭГАН Court appointed by Aliaksandr Lukashenka. He was formerly a judge of the Moskovsky District Court of Brest and judge of the city of Baranovichi in Evgeni Anatolevich Евгений Анатольевич DOB: 26.3.1982 the Brest region. He issued sentences against a large number of citizens of BREGAN БРЕГАН Nationality: Belarusian Belarus accused, amongst other things, of having taken part in the protests against the Belarusian regime in August 2020. Gender: male He is therefore responsible for the repression of civil society. Personal ID: 3260382K020PB0 4/13 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj EN OJ L, 16.12.2024Names (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 270. Aliaksandr Mikalaevich Аляксандр Мікалаевіч Judge of the Soviet District Aliaksandr Mokhorau a Belarusian judge who has served in the Soviet 16.12.2024 MOKHORAU МОХОРАЎ Court of the city of Gomel District Court of the city of Gomel since 2021. He was appointed by Aliaksandr Lukashenka. He issued sentences against citizens of Belarus Alexander Nikolaevich Александр Николаевич DOB: 16.4.1986 who voiced their opinions against the President, the system and brutality MOKHOREV МОХОРЕВ Nationality: Belarusian of Belarusian law enforcement structures. Gender: male He is therefore responsible for repression of civil society. Personal ID: 3160486H031PB9 271. Alesya Uladzimiravna Алеся Уладзіміраўна Judge of the Central District Alesya Osipava is a Belarusian judge who has served in the Central District 16.12.2024 OSIPAVA ОСIПАВА Court of the city of Gomel Court of the city of Gomel since 2019. She was appointed by Aliaksandr Lukashenka. She issued sentences against citizens of Belarus who voiced Olesya Vladimirovna Олеся Владимировна DOB: 4.9.1979 their opinions against the President, the system and brutality of Belarusian OSIPOVA ОСИПОВА Nationality: Belarusian law enforcement structures. Gender: female She is therefore responsible for the repression of civil society. Personal ID: 4040979H059PB4 272. Viktar Viktaravich Віктар Віктаравіч НОВIК Judge, President of the Court, Viktar Novik is a Belarusian judge who has served in the Zhabinka District 16.12.2024 NOVIK Zhabinka District court since 2017. He was appointed by Aliaksandr Lukashenka. Novik Виктор Викторович issued numerous rulings against opponents of the Belarusian authorities. Viktor Viktorovich НОВИК DOB: 27.5.1963 He issued politically motivated prison sentences against Vitali NOVIK POB: Beloye, Mamlyutsky Ivanyukovich (2 years), Natalia Letsko (1 years), Andrei Vlasov and Yulia district, North Kazakhstan Suvalko (3 years) and Valentin Shumik (2 years). region, Kazakhstan He is therefore responsible for the repression of civil society. Nationality: Belarusian Gender: male Personal ID: 3270563K025PB7 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj 5/13 OJ L, 16.12.2024 ENNames (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 273. Vadzim Rastivlavovich Вадзім Расціслававіч Head of the correctional Vadzim Murashka is a Belarusian national and head of the correctional 16.12.2024 MURASHKA МУРАШКА institution Penal Colony No 13 institution Penal Colony No 13, a maximum-security prison where a number of political prisoners are held, including Nikolai Statkevich, Vadim Rostslavovich Вадим Ростиславович DOB: 20.6.1979 Vitaly Melnik and Sergei Vereshkhagin. Prisoners of Colony No 13 face MURASHKO МУРАШКО POB: Bortniki, Hlybokaye inhumane conditions and are subject to abuses. District, Vitebsk Region, Belarus He is therefore responsible for serious violations of human rights and Nationality: Belarusian repression of civil society. Gender: male Personal ID: 3200679E065PB6 274. Siarhei Uladzimiravich Сяргей Уладзіміравіч Deputy head of Pre-trial Siarhei Biareishyk is the deputy head of Pre-trial Detention Centre No 1 16.12.2024 BIAREISHYK БЯРЭЙШЫК Detention Centre No 1 “Voldarka”. In this position, he is responsible for the inhumane treatment “Voldarka” of the detainees, including beatings, overcrowding and lack of appropriate Sergey Vladimirovich Сергей Владимирович medical treatment and sanitary equipment. The majority of inmates are BEREISHIK БЕРЕЙШИК DOB: 31.10.1976 political detainees, such as human rights activist, founder of Belarusian POB: Minsk, Belarus human rights association Viasna and 2022 Nobel Peace Prize Winner Ales Bialiatski, who was detained in “Voldarka” until October 2024. Nationality: Belarusian Siarhei Biareishyk is therefore responsible for serious violations of human Gender: male rights and repression of civil society. Personal ID: 3311076A076PB6 6/13 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj EN OJ L, 16.12.2024Names (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 275. Mikalai Mikalaevich Мікалай Мікалаевіч Deputy head of labour service Mikalai Mushkarou is the deputy head of labour service in the Pre-trial 16.12.2024 MUSHKAROU МУШКАРОЎ in Pre-trial Detention Center Detention centre No 1 “Voldarka”. In this position, he is responsible for No 1 “Voldarka” the inhumane treatment of the mainly political detainees, including Nikolai Nikolaevich Николай Николаевич beatings, overcrowding and lack of appropriate medical treatment and MUSHKAROV МУШКАРОВ DOB: 19.12.1980 sanitary equipment. The majority of inmates are political detainees, such POB: Minsk, Belarus as human rights activist, founder of Belarusian human rights association Viasna and 2022 Nobel Peace Prize Winner Ales Bialiatski, who was Nationality: Belarusian detained in “Voldarka” until October 2024. Gender: male Mikalai Mushkarou is therefore responsible for serious violations of human rights and repression of civil society. Personal ID: 3191280A031PB0 276. Siarhei Mikalaevich Сяргей Мікалаевіч Head of the correctional Siarhei Petrakovich is the head of Penal Colony No 9. In this position he is 16.12.2024 PETRAKOVICH ПЕТРАКОВIЧ institution Penal Colony No 9 responsible for the inhumane treatment of prisoners, including isolation and beatings. The majority of the inmates are political prisoners, such as Sergey Nikolaevich Сергей Николаевич DOB: 26.10.1976 Mikola Dedok and the 2022 Nobel Peace Prize winner Ales Bialiatski. PETRAKOVICH ПЕТРАКОВИЧ POB: Stan, Gorki District, Siarhei Petrakovich is therefore responsible for serious violations of Mogilev Region, Belarus human rights and the repression of civil society. Nationality: Belarusian Gender: male Personal ID: 3261076M062PB5 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj 7/13 OJ L, 16.12.2024 ENNames (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 277. Viktar Piatrovich Віктар Пятровіч Head of the medical unit, Prison Viktar Luttsau is the head of the medical unit in Prison No 1 in Grodno. In 16.12.2024 LUTTSAU ЛУТЦАЎ No 1 in Grodno this position, he is responsible for the inhumane treatment of detainees and lack of appropriate and timely medical assistance. The lack of proper Viktor Petrovich Виктор Петрович DOB: 24.12.1985 medical treatment led to the death of political prisoner Ales Pushkin, who LUTSEV ЛУТЦЕВ POB: Grodno, Belarus was not provided timely medical assistance. Nationality: Belarusian He is therefore responsible for serious human rights violations and the repression of civil society. Gender: male Personal ID: 3241285K026PB1 278. Ihar Tsimafeevich Iгар Цімафеевіч Businessman Ihar Subotsin is a long-term close business associate of Alexander 16.12.2024 SUBOTSIN СУБОЦIН Shakutin. Ihar Subotsin has been working with Alexander Shakutin since DOB: 15.10.1951 the early 1990s and was also his assistant when Alexander Shakutin was Igor Timofeyevich Игорь Тимофеевич POB: Belarus a member of the Council of the Republic of the National Assembly of the SUBBOTIN СУББОТИН Republic of Belarus and his deputy at the Belarusian Tennis Federation. Nationality: Belarusian Both Alexander Shakutin and Ihar Subotsin are shareholders in the Gender: male following companies: SIA Anulatrans (Latvia), SV Maschinen GmbH (Germany), PMI Engineering LLC (Belarus), SALEO LLC (Belarus), UAB EM Personal ID: 3151051A006PB8 System (Lithuania). They are co-founders and co-owners of Prommedinvest, which is now named SALEO LLC (Belarus). This company is also partially owned by EM System, PMI Engineering, and SV Maschinen GmbH, of which both Shakutin and Subotsin are shareholders. Ihar Subotsin is therefore associated with Alexander Shakutin. 8/13 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj EN OJ L, 16.12.2024Names (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 279. Aliaksei Ivanovich Аляксей Iванавіч Chairman of the Belarusian In his role as Chairman of the Belarusian Republican Bar Association, 16.12.2024 SHVAKAU ШВАКОЎ Republican Bar Association Aliaksei Shvakau has been leading and shaping the the Belarusian (since 14 February 2022); Republican Bar Association policy of systemic repression against lawyers Alexey Ivanovich Алексей Иванович former chairman of the Minsk who represent clients in politically motivated cases or who speak out SHVAKOV ШВАКОВ City Bar Association (26 April against abuses by the Lukashenko regime. In his former role as chairman 2012–20 February 2022) of the Minsk City Bar Association, he also targeted lawyers representing clients in politically motivated cases. DOB: 5.10.1964 He is therefore responsible for the repression of civil society and Nationality: Belarusian democratic opposition and activities that undermine the rule of law in Gender: male Belarus. Passport number: 3051064A050PB 280. Aleh Genadzevich Алег Генадзевіч АРЛОЎ DOB: 18.7.1969 Aleh Arlou is a businessperson operating in Belarus. He is the owner of 16.12.2024 ARLOU Ruzekspeditsiya LLC since 7 August 2023. Олег Геннадьевич POB: Azerbaijan Oleg Gennadievich ОРЛОВ Since 2019 Aleh Arlou’s company has conducted its business from the Nationality: Belarusian ORLOV Bremino-Orsha Special Economic Zone (SEZ), established by a presidential Gender: male decree of Aliaksandr Lukashenka, which is managed by Bremino Group LLC. Companies established in the Bremino-Orsha Special Economic Zone Passport number: MP3428828 profit from tax and other financial advantages. Bremino-Orsha SEZ is home to and therefore gives these benefits to only six companies, including Bremino Group LLC. The decision as to who is allowed to share in the benefits of the Bremino-Orsha SEZ by becoming its resident, lies solely with Bremino Group LLC as the managing company of the SEZ. According to journalists’ investigations, Ruzekspeditsiya is involved in a sanctions evasion scheme concerning Council Regulation (EC) No 765/2006. It follows that Arlou is associated with entities listed under Regulation (EC) No 765/2006, namely Ruzekspeditsiya LLC and Bremino Group. Through his ownership of the company he also benefits from the advantages granted to Ruzekspeditsiya LLC by the regime. He also partakes in a scheme designed to frustrate Council Regulation (EC) No 765/2006. ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj 9/13 OJ L, 16.12.2024 ENNames (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 281. Andrei Aliakseevich Андрэй Аляксеевіч Director-General of OAO Andrei Rybakou is the Director-General of OAO Belaruskali. He was 16.12.2024 RYBAKOU РЫБАКОЎ Belaruskali appointed by Aliaksandr Lukahsenka on 4 November 2024, replacing Ivan Golovaty. Lukashenka described Belaruskali as a “vital state-forming Andrei Alekseevich Андрей Алексеевич Former Chairman of the enterprise”. RYBAKOV РЫБАКОВ Belarusian State Concern for Oil and Chemistry (Belneftekhim) Previously, Rybakou was the Chairman of the Belarusian State Concern for Oil and Chemistry (Belneftekhim), sanctioned by the EU since 3 August DOB: 11.7.1976 2023. In that capacity, he was responsible for the output of Belarusian oil POB: Mohiliow (Mogilev), refineries, a vital operation for the Lukashenka regime. Dmitri Krutoi, the Belarus Head of the Belarus President Administration, stated that Rybakou was appointed specifically for his “specific experience” running “the most Nationality: Belarusian sanctioned” entity – Belneftekhim. Therefore, Andrei Rybakou benefits from and supports the Lukashenka regime by managing state-owned Gender: male companies of great importance to the regime. He is also associated with sanctioned entity OAO Belaruskali, as its Director-General. 282. Aleh Fyedaravych Алег Федаровіч DOB: 29.8.1956 Aleh Barabanau is the director and part-owner of Vlate Logistik LLC, 16.12.2024 BARABANAU БАРАБАНАЎ a transport and storage company which holds the status of authorised POB: Grodno region, Belarus economic operator. Through this status, issued by state authorities, it Oleg Fedorovich Олег Федорович Nationality: Belarusian enjoys significant tax advantages. Through the privileges awarded to the BARABANOV БАРАБАНОВ company, Barabanau benefits from the Lukashenka regime. Gender: male Passport number: KH2539329 National ID:3290856K010PB6 10/13 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj EN OJ L, 16.12.2024Names (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 283. Aleh Ramualdavych Алег Рамуальдавіч DOB: 3.3.1962 Aleh Herasim is part-owner of Vlate Logistik LLC, a transport and storage 16.12.2024 HERASIM ГЕРАСIМ company which holds the status of authorised economic operator. POB: Belarus Through this status, issued by state authorities, it enjoys significant tax Oleg Romualdovich Олег Ромуальдович Nationality: Belarusian advantages. Through the privileges awarded to the company, Herasim GERASIM ГЕРАСИМ benefits from the Lukashenka regime. Gender: male Passport number: MP3293367 National ID: 3030362A074PB6 284. Aleh Uladzimiravych Алег Уладзіміравіч DOB: 26.3.1962 Aleh Piatrou is part-owner of Vlate Logistik LLC, a transport and storage 16.12.2024 PIATROU ПЯТРОЎ company which holds a status of authorised economic operator. Through POB: Russia this status, issued by state authorities, it enjoys significant tax advantages. Oleg Vladimirovich Олег Владимирович Nationality: Russian Through the privileges awarded to the company, Piatrou benefits from the PETROV ПЕТРОВ Lukashenka regime. Gender: male Passport no.: OI110473 285. Andrei Ryhoravich Андрэй Рыгоравiч Financial director of Andrei Svirydau is the financial director of Dimicandum Invest Holding 16.12.2024 SVIRYDAU СВIРЫДАЎ Dimicandum Invest Holding LTD, a company established in the EU. In 2022 and 2023, Dimicandum LTD Invest Holding LTD provided transport and forwarding services to OJSC Andrei Grigoryevich Андрей Григорьевич Belaruskali – which has been designated by the Union since 2022 – at SVIRIDOV СВИРИДОВ DOB: 24.11.1983 a price nearly double the market rate. As financial director of POB: Belarus Dimicandum, Svirydau signed documents confirming this deal, facilitating the undermining of the provisions set out in Council Nationality: Belarusian Regulation (EC) No 765/2006. Gender: male It follows that by making funds or economic resources available, directly or indirectly, to or for the benefit of OJSC Belaruskali, Andrei Svirydau has Passport number: KH 1801845 significantly frustrated the prohibition against circumvention of Art. 2(2) of Council Regulation (EC) No 765/2006. Moreover, Andrei Svirydau is benefitting from and supporting the Lukashenka regime by facilitating the export of Belaruskali’s potash fertilisers. ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj 11/13 OJ L, 16.12.2024 ENNames (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) 286. Dzmitry Mihaylavych Дзмітрьій Міхайлавіч Part-owner of Vlate Logistik LLC Dzmitry Zamulevich is part-owner of Vlate Logistik LLC, a transport and 16.12.2024 ZAMULEVICH ЗАМУЛЕВIЧ storage company which holds the status of authorised economic operator. DOB: 7.5.1974 Through this status, issued by state authorities, it enjoys significant tax Dmitriy Mikhailovich Дмитрий Михайлович Nationality: Belarusian advantages. Through ownership of Vlate Logistik LLC, Zamulevich is ZAMULEVICH ЗАМУЛЕВИЧ associated with an entity benefitting from the Lukashenka regime. Gender: male Belarusian passport number: BM2229283 Belarusian ID:3070574E057PB8 287. Uladzimir Mihaylavych Уладзімір Міхайлавіч Part-owner of Vlate Logistik LLC Uladzimir Arkadzyeu is part-owner of Vlate Logistik LLC, a transport and 16.12.2024’. ARKADZYEU АРКАДЗЬЕЎ storage company which holds the status of authorised economic operator. DOB: 23.4.1965 Through this status, issued by state authorities, it enjoys significant tax Vladimir Mikhailovich Владимир Михайлович POB: Russia advantages. Through ownership of Vlate Logistik LLC, Arkadzyeu is ARKADIEV АРКАДЬЕВ associated with an entity benefitting from the Lukashenka regime. Nationality: Russian and Belarusian Gender: male Belarusian passport number: KH2757270 Belarusian ID: 3230465K000PB5 Russian passport number: KH1935655 12/13 ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj EN OJ L, 16.12.2024(2) the following entries are added to the list set out in section ‘B. Legal persons, entities or bodies referred to in Article 2(1)’: Names (Transliteration of Names Belarusian spelling) (Belarusian spelling) Identifying Information Reasons for listing Date of listing (Transliteration of Russian (Russian spelling) spelling) ‘39. Ruzekspeditsiya LLC TAA “Рузэкспедыцыя” Address: 1K Zavodzkaya St., Ruzekspeditsiya LLC conducts its business from the Bremino-Orsha 16.12.2024 room 36 Bolbasovo 211004 Special Economic Zone (SEZ) established by a presidential decree of RUZSPEDITION LLC OOO “Рузэкспедиция” Belarus; Aliaksandr Lukashenka, which is managed by Bremino Group LLC. OOO RUDENSKI Bremino Group LLC was listed in Annex I of Council Regulation (EC) 40 Nemiga St., room 304 Minsk UDOBRENCHESKI No 765/2006. Companies established in the Bremino-Orsha Special ZAVOD 220004 Belarus Economic Zone profit from tax and other financial advantages. OBSHCHESTVO Date of registration: 6.1.2016 Bremino-Orsha SEZ is home to and therefore gives these benefits to only S OGRANICHENNOI Registration number: six companies, including Bremino Group LLC. The decision as to who is OTVETSTVENNOSTYU RUZEKSPEDITSIYA 690664113 allowed to share in the benefits of the Bremin-Orsha SEZ by becoming its resident lies solely Bremino Group LLC as the managing company of the Email address: info@ruz.by SEZ. Tel. + 375296615929; For the reasons set out above, Ruzekspeditsiya is associated with Bremino Group LLC. As a company established in the Bremino-Orsha SEZ it +375172006232 benefits from the regime. Ruzekspeditsiya also facilitates infringements of Website: https://ruz.by/ the prohibition against circumvention of the provisions of Council Regulation (EC) No 765/2006 by participating in the delivery of cars prohibited to be sold, supplied, transferred or exported from the Union to Belarus. 40. Vlate Logistik LLC ТАА “ВЛАТЭ Лагістык” Address: 48 Komarova St., Vlate Logistik LLC is a Belarusian company which owns two border 16.12.2024’. Pogranichny, 231773, Belarus checkpoints on EU-Belarus border. As of 10 August 2023, Aleh Herasim, ООО “ВЛАТЕ Логистик” Aleh Piatrou, Iryna Kalesnikava, Aleh Barabanau, Dzmitry Zamulevich, Date of registration: 16.4.2013 and Uladzimir Arkadzyeu owned equal shares of Vlate Logistic LLC. Vlate Registration number: Logistik LLC benefits from the regime through having the status of 192003422 “authorised economic operator”, which allows for significant tax exemptions and is issued by state authorities. ELI: http://data.europa.eu/eli/reg_impl/2024/3177/oj 13/13 OJ L, 16.12.2024 EN

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