Stance of the UNIMOT Group and information package on sanctions for Belarus

Date of publication: 19.07.21

Dear Sirs,

With regard to extending by the European Union the sanctions imposed on Belarus after the Belarusian services brought a Ryanair airline plane to a forced landing in Minsk, in May 2021, and detention by the Belarusian authorities of a journalist Raman Pratasiewicz and Sofia Sapiega, in response to your expectations and needs, we would like to provide you with a comprehensive package of information on this topic.

The most important message that we want to pass to you is that the Unimot Group as a responsible trade partner declares compliance with all the regulations in force, therefore after 25th June 2021 we do not import fuel from Belarus, apart from products imported pursuant to contracts concluded before 25th June 2021, which is in line with the guidelines of the European Union. Simultaneously, below you can find a package of information that will help you structure your knowledge about currently valid regulations and guidelines pertaining to trading fuels with Belarus.

We would also like to assure you that we hold a fully-secured volume of supplies and maintain full operating liquidity. We are following and analysing on an ongoing basis the impact of imposed sanctions on the activity of the Unimot Group, and so on the offer we present to you. We make every effort to make you feel the impact of the sanctions in the least degree. We will keep you informed about all our steps.

Yours faithfully,

Robert Brzozowski

Vice-President of the Management Board of UNIMOT S.A. for Commercial Affairs

Extension of the sanctions imposed on Belarus since 25th June 2021 – most important information

on 24th June 2021 the European Union extended the range of sanctions in force in the trade relations with Belarus, which cover, among others, import of petroleum products (diesel, petrol, LPG). The new range of sanctions has been in force since Friday, 25th June 2021.

The new economic sanctions (restrictive measures), of unprecedented economic nature, are a direct reaction of the European Union to bringing a Ryanair airline plane to a forced landing of in Minsk, Belarus, in May 2021 and detention by the Belarusian authorities of the journalist Raman Pratasiewicz and Sofia Sapiega. They constitute part of so-called fourth package of sanctions.

The sanctions were introduced pursuant to the Regulation of the Board (EU) 2021/1030 of 24th June 2021, which amends the Regulation 765/2006 of 18th May 2006. Of key importance for trading petroleum products are the provisions of the new Article 1 h items 1-3. The range of products, according to CN codes, has been specified in Appendix V to the Regulation 2021/1030. Therefore, the sanctions cover, among others, diesel, petrol, LPG (hence called “Products”).

In accordance with the amended range of sanctions, since 25th June 2021 it has been forbidden to:

import to the EU Products that come from Belarus or are subject of export from Belarus;
purchase Products that are located in the territory of Belarus or come from Belarus and
transport Product, if they come from Belarus or are a subject of export from Belarus to any other country;
provide technical assistance, services, brokerage services, financing or financial assistance, insurance and reinsurance related to the activities stipulated in items 1-3 above.

Import, purchase or transport of Products (items 1-3 above) have been excluded from the range of sanctions if they occur in execution of agreements concluded prior 25th June 2021.

The imposed sanctions have to be executed by all physical and legal persons operating within the territory of the European Union and by EU entities that conduct activity abroad.

Consequences of infringement to the EU sanctions have been left at the discretion of the EU member states, with a reservation that they need to be effective, proportional and disuasive.

Although the range of sanctions seems to be clear as to its wording, due to the attitude of the National Tax Administration the practice of trading Products that come from the territory of Belarus since 25th June 2021 currently casts serious doubts and discrepancies with regard to particular groups of Products.