Introduction

On 4 November, the US Department of the Treasury announced that it had formally lifted sanctions on Belarus’s national airline Belavia, as well as on a Bombardier jet operated by the airline. The aircraft is reportedly used by senior government officials and members of President Alexander Lukashenko’s family. Apart from the official notice of Belavia’s removal from the OFAC list, the US has not provided further comment on the announcement.

This move marks the latest development in US-Belarus relations, following the partial easing of sanctions in September, when the US permitted Belavia to service and purchase components for its aircraft, after the country released 52 of its political prisoners following a direct appeal made by US President Donald Trump to Lukashenko. While Lukashenko described the event as a “humanitarian gesture,” it was met with a great deal of controversy, both regarding the circumstances of the prisoners’ release and the broader implications of easing sanctions.  

In response to the news, many Belarusian oppositional figures, including former presidential candidate Sviatlana Tsikhanouskaya, denounced the release as “a forced deportation,” with individuals sent to cross the border with Lithuania with “no passports” and unable to return home to their families.

Beyond human rights concerns, EU officials and political analysts have drawn attention to the close relationship between Russia and Belarus, and how the easing – and lifting – of sanctions could increase the risk of parallel imports and sanctions evasion, particularly where parts destined for Belarus may ultimately be smuggled into Russia.

As part of the September announcement, the US Department of Commerce sent a letter to Belavia’s General Director, Ihar Charhinets, specifying that the airline remains prohibited from operating Boeing flights to or from Russia, the occupied regions of Ukraine, Iran, Syria, Cuba and North Korea. The restrictions also extend to the Boeing 767 (registration number EW001PA) reportedly used by Lukashenko’s family, and to any aircraft used for transporting goods that “support Russia’s military actions.”

‍

But is it guaranteed that Belavia will comply with these requirements?

Now that the sanctions on Belavia have been fully lifted, it is more important than ever to examine how this decision may affect both the airline’s and Belarus’s relationship with Russia; and the accompanying risks of sanctions evasion and parallel trade.

Continue reading for a deep dive into the reasons why Belavia was sanctioned in the first place, its ties with Russia, the implications of the recent sanctions relief, and what businesses and individuals can do to avoid entanglement in associated risks.

‍

Why was Belavia sanctioned?

On 23 May 2021, a Ryanair flight travelling from Athens, Greece to Vilnius, Lithuania, received a warning from Belarusian authorities about a potential ‘bomb threat’ if it continued on its route to Lithuania. Although standard protocol would normally divert aircraft in the area to Poland or the Baltic states, Minsk Air Traffic Control insisted on the plane landing in Minsk, claiming that the pilots could not seek advice from Ryanair’s operations control centre in Poland, due to Polish controllers allegedly not answering the phone.

Upon landing, two passengers – exiled Belarusian journalist Raman Pratasevich and his partner Sofia Sapega – were arrested by local authorities. The incident triggered widespread international condemnation, prompting the EU, UK, US and Canada to impose coordinated sanctions and travel restrictions against Belarusian officials and entities. The EU banned all Belarusian airlines from entering or overflying EU airspace and instructed European carriers to avoid Belarusian airspace entirely. The UK followed suit, suspending Belavia’s air service permit and banning British airlines from flying over Belarus.

‍

‍

‍

Later that year, Belavia faced further accusations of facilitating illegal border crossings through Belarus into the EU, particularly through Lithuania, Poland and Latvia; and of participating in the “instrumentalisation of migration” for political purposes. In response, the EU, US, UK and Canada jointly imposed additional sanctions on Belarus, this time directly targeting Belavia.

Since then, these countries continued to expand measures against Belarus and Belavia through 2023 and 2024, in response to Belarus’s support forRussia’s full-scale invasion of Ukraine, launched on 24 February 2022. Therefore, despite the recent US decision to lift its sanctions, Belavia remains subject to EU restrictions, preventing the airline from flying over EU airspace, using EU airports, or operating transatlantic routes that transit EU territory.

This divergence in approach between the US and the EU is likely to feature prominently in future policy discussions. In particular, EU leaders will need to determine whether to restrict the transit of US-manufactured aircraft components through their territories to Belarus. Beyond this, both regulators and businesses should closely monitor another key risk shaped by geopolitics: Belarus’s close alignment with Russia.

‍

Belarus and Russia

It is no secret that Belarus and Russia have been tight-knit allies for years, with the former providing its territory as a staging ground for Russia’s northern invasion of Ukraine in February 2022 and later assuming a supporting role as a supplier of military equipment, munitions and components.

On 12 September, a day after the US announced the initial easing of sanctions on Belavia, Belarus and Russia held their biennial joint military exercise, “Zapad-2025”. The term ”Zapad“ translates from Russian as “West”; and the exercise has long served as a political and military platform for Moscow to showcase its alliance with Minsk and to signal its strategic preparedness toWestern observers.

On 16 September, the Pentagon confirmed that US military officials attended “Zapad-2025” and observed joint war games between Russia and Belarus.This was the first time the country had accepted an invitation since Russia’s2022 invasion of Ukraine, as reported by Reuters. Chief Pentagon spokesperson,Sean Parnell, told Reuters that the US has accepted the invitation due to, “recent productive bilateral engagements between our countries.”

It remains unclear whether the US’s apparent efforts to foster a warmer relationship with Belarus (whose alignment with Russia remains firm)reflect a broader, long-term strategic shift. What is clear, however, is that authorities and businesses closely monitor Belavia and assess whether the airline is indeed meeting its obligations under the 11 September agreement outlined by the US Department of Commerce.

‍

Belavia’s relationship with Russia

Belavia Belarusian Airlines is the flag carrier of Belarus and a state-owned company. Following the collapse of the Soviet Union in 1991, Belarus transformed its Association of Civil Aviation into Belavia, formally established on 5 March 1996. Throughout its history, Belavia has maintained close cooperation with Russia and Russian carriers, a relationship that has only deepened following the 2022 Russian invasion of Ukraine and the subsequent imposition of sanctions on both countries’ aviation sectors.

Among the most recent examples of this partnership, Belavia and Russia’s Utair Airlines launched a major codeshare agreement in March 2025, covering routes between Moscow Vnukovo airport and several Russian cities, including Grozny, Krasnoyarsk and Makhachkala. Around the same time, Belavia signed similar agreements with Russian Nordwind Airlines and Red Wings Airlines.

Under the conditions set out in the US Department of Commerce’s September letter, Belavia is prohibited from operating flights to or from Russia, the occupied regions of Ukraine, Iran, Syria, Cuba and North Korea.

However, analysis conducted by Themis, drawing on data from Russian and Belarusian travel engines (such as Aviasales) and flight-tracking platforms including FlightAware and Flightradar24, indicates that Belavia has continued to operate regular flights to and from Russia, most notably flight BRU939 from Minsk to St Petersburg’s Pulkovo Airport, operated using a Boeing 737-300. FlightAware data shows this route scheduled daily through at least 13 November 2025.

Russia’s aviation portal has also reported that Belavia’s Boeing flights to Russia demonstrate the “limited effectiveness of US sanctions.” In October 2025 alone, Belavia reportedly operated flights from Minsk to Moscow, St Petersburg, Yekaterinburg, Sochi and Makhachkala, using aircraft registered as EW366PA, EW254PA (both Boeing 737-300), and EW455PA (Boeing737-800).

‍

‍

Furthermore, despite explicit restrictions on the use of the Boeing767 (registration EW001PA), reportedly used by Lukashenko’s family, the aircraft was last recorded in operation on 26 September 2025 in Minsk.

Belavia’s attempts to circumvent sanctions are not new. Just two months prior to the September announcement, the airline was reported to have acquired three Airbus A330-200 aircraft through a covert deal that appeared to bypass Western restrictions.

According to Reuters, Belavia purchased the planes after being deregistered from their previous owner – Gambia-based airline Magic Air. The investigation found that upon landing in Minsk on 17 August 2024, all three planes were still registered under Magic Air, but were subsequently deregistered in Gambia and re-registered in Belarus under the tail numbers EW-587PD, EW-588PD and EW-589PD.

In March2025, media sources reported that Belavia – previously without experience operating Airbus or long-haul wide body aircraft – was seeking crew retraining assistance from Russia’s Aeroflot PJSC. Flightradar24 data confirms that the EW-587PD and EW-588PD aircraft are now in daily operation on routes to Istanbul, Hambantota, Dubai and Sanya, while EW-588PD was also recorded flying to and from Moscow on 31 October 2025. The EW-589PD aircraft does not appear to be currently in service.

Meanwhile, in June 2025, Finnish journalist consortium Yle published an investigation revealing that Russia has continued to import aircraft parts from Boeing and Airbus despite sanctions, worth an estimated EUR 1 billion since 2022. The investigation uncovered a network of around 360 companies involved in facilitating these imports, many of which were subsequently added to Western sanctions lists.

The top exporters of airplane parts were companies based in the United Arab Emirates, Gabon, China and Turkey. The shipments were recorded as including not only cabin supplies, but also critical components such as engines, radar systems and onboard computers. The primary recipients of these shipments were airlines operating civilian flights.

According to Investigate Europe, cited by The Moscow Times, India has also exported more than 700 consignments of aircraft parts to Russia since 2022. Among the recipients was Utair, Belavia’s new partner, which reportedly received around one-quarter of these shipments. Other beneficiaries included listed were Aeroflot, its subsidiaries Pobeda and Rossiya, and Ural Airlines.

Most recently, on 29 October, Belavia signed a preliminary memorandum of mutual cooperation with the Russian United Aircraft Corporation to purchase domestically produced MS-21 and Superject aircraft, further cementing its partnership with the country.

‍

Next steps

The picture is clear: Belavia shows no signs of scaling back its cooperation with Russia or Russian airlines anytime soon. So, what can firms do to protect themselves from inadvertently becoming entangled in parallel imports and sanctions breaches?

This is where Themis can help. By providing thorough and holistic Enhanced Due Diligence investigations, we trace and uncover complex financial crime and reputational risks, debunking complex layers of connections and corporate structures.

While Belavia’s full compliance with global sanctions cannot be guaranteed, conducting thorough due diligence provides confidence and assurance. Our team leverages expert knowledge of the financial crime landscape, combined with open-source intelligence (OSINT) and advanced research techniques to navigate these complexities effectively.