Obstruction of Access by Belarusian Exiles to Financial Services: The Impact of Transnational Repression by the Lukashenka regime 

iSANS, Dr. Natasza Krawczyk, Yuri Dzhibladze    ×   
2 September 2026
Obstruction of Access by Belarusian Exiles to Financial Services: The Impact of Transnational Repression by the Lukashenka regime
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In recent years, transnational repression (TNR) has become an integral part of Lukashenka’s repressive policy, aimed at punishing exiled dissenters and silencing their critical voices.[1] Despite a steady increase in the regime’s use of TNR and an expansion in the categories of targeted Belarusian exiles, the international community has only recently begun to pay attention to this phenomenon.[i] Today, Belarus is widely recognised as one of the countries most frequently resorting to TNR.[2]

This paper provides an overview of the instruments of transnational repression actively employed by the Lukashenka regime to obstruct Belarusian exiles’ access to financial services. Two such tools are used for this purpose: the abuse of international financial control frameworks and the denial of consular services. We present recent examples drawn from cases recorded in 2025-2026. In light of the regime’s increasingly active deployment of these instruments, we propose a number of recommendations for intergovernmental organisations and the authorities of host countries.

The impact of the status of a “terrorist” or an “extremist” on access to banking services

Several of TNR-based methods of repression employed by the Lukashenka regime are grounded in the designation of a person as a “terrorist” or an “extremist” and their subsequent inclusion in the related lists maintained by the Belarusian authorities – the List of Organisations and Individuals Involved in Terrorist Activities and/or the List of Citizens of the Republic of Belarus, Foreign Citizens, and Stateless Persons Involved in Extremist Activities in the Republic of Belarus. Individuals are included in these lists even in the absence of court verdicts. These lists are regularly updated and expanded. Inclusion in these lists is arbitrary and is widely used to persecute people on political grounds. Belarusian legislation allows a broad range of grounds for designation of a person as a terrorist or an extremist, including for a donation to or another association with an organisation or an informal initiative included in a separate list of “extremist formations” or for a subscription to or re-posting of “extremist material” included in yet another list.[3] De-listing procedures remain opaque, and effective remedies are lacking.

As of mid-August 2026, the “List of Organisations and Individuals Involved in Terrorist Activities” included 1,475 persons, of whom more than 726 were Belarusians.[4] The “List of Citizens of the Republic of Belarus, Foreign Citizens, and Stateless Persons Involved in Extremist Activities in the Republic of Belarus” included 6,819 persons.[5]

Individuals included in these lists face severe limitations both inside Belarus and in exile. Inside the country, these include barriers to employment and education, and, in the case of those designated as “terrorists”, restrictions on SIM cards, banking and basic financial transactions.[6] Mandate holders of several special procedures of the UN Human Rights Council raised allegations of intentional ill-treatment of prisoners designated as “extremists” or “terrorists”. Furthermore, concerns persist that such prisoners face severe restrictions on receiving money transfers and packages, leaving them dependent on inadequate provisions from penitentiary institutions.[7]

For Belarusians in exile, designating an individual as a “terrorist” or an “extremist” enables TNR through search and extradition mechanisms within the Interpol system or via interstate cooperation in criminal matters.

The objectives of such listings are not limited to securing a forced return of individuals to Belarus and their subsequent criminal prosecution. The Lukashenka regime systematically weaponises international financial control frameworks to create serious obstacles to the daily lives and economic activities of Belarusian exiles.

Recognition of a person as a “terrorist” or an “extremist” triggers automated alerts in global financial compliance databases, designed to combat money laundering and financing of terrorism to implement the requirements of the Financial Action Task Force (FATF), a global inter-governmental organisation.[8] These databases, maintained by private providers such as LexisNexis, Sumsub, Dow Jones Risk & Compliance, and LSEG, incorporate national sanctions lists, information about politically exposed persons, and adverse media mentions. These databases are consulted by financial institutions worldwide during the mandatory customer due diligence procedure. Importantly, the process of compiling information for the databases is 95-99% automated. Algorithms scan news, court decisions, and government websites. When an individual’s status changes, banks receive online notifications from the databases flagging the person’s “association with terrorism”.[9]

Banks then must decide whether to investigate further or simply terminate the relationship with the customer. Given that national financial regulators impose steep fines on banks for missed risks (recent examples include Canadian TD Bank’s payment of 3.09 billion USD in fines and penalties in 2024 for enabling money laundering and violations of the Bank Secrecy Act,[10] and a fine of 125 million USD imposed on the Swiss UBS Financial Services Inc. in August 2026 for repeatedly violating anti-money laundering rules[11]), but impose no penalties for excessive caution in applying the due diligence procedures, the choice for banks striving to avoid risks is obvious.[12] Without further clarification of the circumstances surrounding an individual’s inclusion on the lists of “extremists” and “terrorists”, banks often restrict even the most innocuous transactions or simply close accounts altogether, preferring to avoid any association with the “problematic client from the list”.[13]  

Representatives of LSEG and LexisNexis confirmed that they incorporate data from jurisdictions where courts may render politically motivated rulings in their databases, but emphasised that the decision on how to use such data is made by banks themselves.[14] They also noted that individuals can send additional information about themselves for the inclusion in their “profile”.

The case of Dzmitri Navosha demonstrates that this avenue is not always effective. Navosha, living in exile co-founder of the Tribuna media project, who was sentenced to 12 years of imprisonment in absentia in Belarus under political charges, was subjected to severe restrictions across Europe, the United Kingdom, and the United States. Transactions from American banks were completely blocked, some accounts in Europe were closed, and protracted complicated negotiations were required to unfreeze others.[15] Although some data providers eventually incorporated the explanatory materials submitted by Navosha, others, including Dow Jones Risk & Compliance, refused to do so. The British regulator, the Information Commissioner’s Office (ICO), which was also approached by Navosha’s lawyers, declined to intervene, stating that, despite concerns about the judicial system in Belarus, it could not challenge foreign courts decisions and that Navosha himself should appeal the verdict in Belarus.”[16] The demand appears quite ironical and demonstrates a total lack of knowledge of the situation in Belarus by the UK state agency and a lack of communication between the regulator and the UK Foreign Office. The latter has led UK’s consistent efforts in the international arena for many years, demanding the end of repression and supporting democratic aspirations of Belarusians.[17] The UK has imposed and expanded sanctions in respect of the Lukashenka regime for undermining democratic principles and the rule of law, serious violations of human rights, repression of civil society and democratic opposition as well as  for facilitating Russia’s aggression against Ukraine[18] – and yet the financial regulator recommends Navosha to appeal his verdict in Belarus.

Even the partial success achieved by Navosha would not have been possible for the majority of ordinary Belarusians who lack the resources to engage expensive legal counsel. Moreover, one person’s success in having additional information included in his/her “profile” within these databases does not alleviate the difficulties faced by other Belarusians denied banking services. The continuous expansion of the regime-drawn lists of “extremists” and “terrorists” ensures a steady flow of new “high-risk” alerts into the global compliance systems, rendering financial security needed for ordinary life impossible for those affected. As a result, hundreds, if not thousands, of Belarusian exiles face obstacles of varying severity in conducting their daily lives in exile, being unable to access banking services.

At the EU level, a clear position on the abuse of financial control frameworks by repressive regimes was finally established in the European Parliament resolution of 16 June 2026 on countering TNR.[19] The resolution introduced a notion of “financial repression” (para. 13) and indicated that “TNR frequently exploits the ordinary operation of host-state administrative, financial, and migration systems, including compliance-driven financial controls, rigid documentation requirements and fragmented data-handling practices, […] as a result, EU institutions and Member States risk their structures being abused by perpetrators, even in the absence of intent or direct cooperation with perpetrator states; […] addressing TNR therefore requires scrutiny of internal EU and national procedures to prevent their exploitation for repressive purposes”. Furthermore, the resolution directly listed the misuse of the  anti-money laundering and countering the financing of terrorism (AML/CFT) standards of FATF among TNR tactics that need to be countered (para. X). It stated that financial TNR involves the misuse by repressive regimes of FATF AML/CFT standards to disseminate false allegations and trigger compliance-based account freezes and de-banking and indicated that these practices deprive affected individuals and organisations of funding and financial services and undermine their livelihoods, civic and political activities (para. Z). In this regard, the resolution called on the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), which constitutes a key EU safeguard mechanism to develop rapid-response mechanisms against abusive freezes and closures and to establish strict limits on data-sharing with perpetrator states (para. Z). Importantly, the resolution stated that “Belarus conducts TNR at an alarming scale, including on EU territory” (para. AF), highlighting its leading role in employing TNR along with Russia, China and Iran.

The resolution suggested a wide range of recommendations to EU financial regulators and relevant supervisory authorities, the European Commission, and EU member states to prevent and address abuses of financial systems as an important instrument of TNR (para 51-57). These include a call on member states’ law enforcement and judiciaries to cooperate with financial regulators to help prevent and address abuses of financial systems and travel databases used to facilitate TNR; a call on EU financial regulators, including the AMLA, to develop safeguards to prevent such manipulation, including pre-freeze verifications, and apply appropriate screening and data protection measures; a call on EU financial regulators to develop victim-centred redress mechanisms to remedy financial manipulation and long-term harm, including public correction mechanisms; a call for increased coordination between financial regulators, entities and relevant supervisory authorities with the relevant EU bodies addressing TNR; a call on the Commission and the member states to establish mechanisms ensuring guaranteed access to basic banking services to individuals credibly at risk of TNR and emergency financial continuity or liquidity mechanisms where repression results in sudden asset freezes; a call on Financial Intelligence Units to identify and systematically analyse TNR-linked financial patterns and report relevant findings to national and EU TNR coordination hubs; a call on the member states to ensure specialised training for law-enforcement, judicial, financial and cybersecurity authorities on identifying TNR-linked financial patterns, including the misuse of FATF, Interpol and travel database tools; and a call on the member states to provide guidance to financial institutions and ensure that their national financial regulators have the mandate to share the data available to them with law enforcement and judiciaries, and establish an effective national complaint and review mechanism.

The recognition at the EU level of the abuse of anti-moneylaundering/counteringthefinancingofterrorism frameworks as a distinct form of TNRat the EUlevelrepresents a significantsteptowardsprotecting the rights of individuals who have been forced to fleerepressionand now resideinEuropeancountries.Otherinternationalorganisationsshouldfollow the EU’s example by declaringtheunacceptability of financialTNRanddeveloping robust policies to combat and deter suchabuses.

At the national level, practical measures are required to deter financial TNR, including that perpetrated by the Lukashenka regime, and to safeguard the rights of targeted exiles. Implementation of the European Parliament resolution on countering TNR into national legislation and policies of EU member states should be a top priority.

The impact of the cessation of consular services on access to banking services

Another problem faced by Belarusian exiles in the financial sector as a result of Lukashenka’s TNR is the refusal of banks to open accounts or the closing of existing accounts once their Belarusian passport expires. In this case, the ground for obstruction of access to financial services is not inclusion of a person in the lists of “terrorists” and “extremists”, but the termination of consular services to Belarusian exiles – another TNR tool of the Lukashenka regime.

Infamous Decree No. 278, pursuant to which the diplomatic missions of Belarus abroad ceased issuing new passports to Belarusians residing abroad and renewing the old ones, was signed by Lukashenka on 4 September 2023.[20]  Since then, the decree has affected the estimated 800,000 Belarusians who live in exile.[21] Many of them are unable to return to Belarus to renew their documents because of the high probability of political persecution. Consequently, their ability to live, travel, work, and access essential services abroad such as medical care, education or banking services is severely limited. UN experts condemned the adoption of this decree and called upon states not to deport Belarusians with expired passports and to assist them in obtaining alternative documents.[22]

Even Sviatlana Tsikhanouskaya, the leader of the Belarusian opposition, faced difficulties in opening an account with a Polish bank after moving to Poland from Lithuania. She stated that the bank refused to open an account because her Belarusian passport had expired. She lives in Poland on the basis of a residence permit and a foreigner’s travel document (dokument podróży dla cudzoziemca).[23] After several unsuccessful attempts, she succeeded in opening a bank account with another bank, but only after she “demonstrated her connection to Poland” where her Office is located.[24]

After Tsikhanouskaya publicly reported her inability to open an account, many Belarusians, including those who had been living in Poland for a long time, wrote to her about the difficulties they had encountered after the expiration of their national passport. This once again confirmed the systemic nature of the problem and the need to develop an institutional solution. One possible solution could be the issuance by the host state of a foreigner’s travel document, as Tsikhanouskaya’s case, in which she managed to open a bank account using such a document, demonstrated. However, the availability of a foreigner’s travel document has not helped many other Belarusians. Banks often refuse to accept it as a full-fledged identity document. Therefore, a clarification from financial regulators is necessary to ensure that a foreigner’s travel document should be accepted by banks as a document confirming the identity of an individual. In the absence of such a clarification, much depends on the discretion of individual bank regulations and individual bank employees. “I myself have come across the fact that a lot depends on the employee who accepts your documents. I was dealing with an employee who was very sympathetic to the fact that banks refuse to open accounts to Belarusians. He really wanted to help, although he took into account certain limitations,” noted Tsikhanouskaya.[25]

An alternative approach has been adopted in Spain. There, the authorities decided to recognise the validity of passports of Belarusian citizens even after their expiration date, which allows Belarusian exiles to effectively interact with government agencies.[26] Unfortunately, because banks do not fall directly under migration regulations, most financial institutions in Spain still require a valid passport to carry out due diligence procedures. The position of each bank is formed at the level of its compliance department and may change.[27] Therefore, additional efforts should be undertaken by the authorities of Spain (and other countries) to secure Belarusian exiles’ access to banking services, even if expired Belarusian passports are recognised by the government as valid.

The first step in this direction could be to secure the right to a “basic bank account” under the EU Payment Accounts Directive (PAD) 2014/92/EU.[28] According to this directive, any consumer legally residing in the EU has the right to open and use a payment account with basic features. Although Article 16(4) of the PAD establishes a ground for refusal – namely, if opening an account would result in a violation of AML/CFT provisions, in its recent case C 81/24,[29] the Court of Justice of the European Union ruled on 11 June 2026 that “Article 16(4) PAD […] must be interpreted as not authorising member states to require credit institutions to refuse to open a basic payment account for a consumer solely on the ground that that consumer is included on a list of persons subject to restrictive measures imposed by a third country, without the credit institution concerned having carried out an individual assessment of the risk of money laundering or terrorist financing associated with the intended business relationship” (para 56). Experts commented that the judgement has immediate and concrete implications for compliance frameworks, including that “blanket screening policies that generate per se refusals are unlawful under EU law. Institutions maintaining such policies are exposed to enforcement action by the competent national authorities and to civil claims from persons wrongly denied accounts.”[30] Relevant efforts on the part of national authorities could therefore assist Belarusian exiles in gaining access to at least basic financial services.

Discrimination in the financial sector based on the principle of belonging to the Belarusian nationality

There is yet another problem that exacerbates the hardships Belarusian exiles face due to TNR by the Lukashenka regime. It is not directly related to TNR and is grounded in over-compliance by banks in the application of EU sanctions against Russia and Belarus. This problem has existed for Belarusian and Russian exiles for several years,[31] but recently it has been exacerbated by the adoption of the 19th package of EU sanctions.[32] The result is what the World Bank calls “de-risking”: banks reject entire categories of clients rather than evaluating individual cases.[33]

Following the adoption in October 2025 of the 19th package of EU sanctions against Russia[34] and its parallel application in respect of Belarus, financial institutions in various European countries began terminating services provided to Belarusian and Russian citizens living in exile simply on the basis of their nationality – or sometimes even by the fact of their birth place in these countries, even where the individuals concerned have acquired permanent residency or citizenship of another state.[35]

Discrimination by financial institutions against clients associated with Belarus can be illustrated by the absurd blocking of a Canadian citizen’s account by the Wise payment system. The Wise AI algorithm suddenly demanded clarification about a connection with Belarus from a user with Canadian citizenship, Canadian financial residency and a Canadian contact phone number who had previously used the system periodically without any problems. The basis of the request was the address specified by the user – Warszawa, ulica Mińska. The user explained that the only thing that connects him with Belarus is the name of the street where he currently lives, but his money transfer and card were blocked.[36]

In its responses to inquiries from organisations of Belarusian democratic forces, the Polish Financial Supervision Authority (KNF) explained that Belarusians may be considered “a high-risk client group,” but this cannot be the sole reason for terminating or denying them service. Therefore, the bank must justify and document each refusal, stated the KNF, but must first ensure that it has “considered all possible measures to mitigate the risk” of the Belarusian citizen.[37]

The EU authorities have recognised that over-compliance by European banks of application of EU restrictive measures leads to discrimination against groups of people based on their nationality. In March 2026, approximately six months after the adoption of the 19th package of sanctions, the European Commission issued clarifications (FAQ) on the application of Art. 5b(2) of Council Regulation 833/2014, introduced as part of the 19th package, where it gave broader explanations regarding the rules governing the operations of European banks with regards citizens of Russia and Belarus.[38] These clarifications stated that having Russian or Belarusian citizenship is not a reason for automatically closing accounts or refusing service if a person has a legal residence status in the EU and therefore does not fall into the scope of restrictive measures. In particular, restrictions imposed by the sanctions do not apply to citizens of Russia or Belarus who also hold citizenship of one of the countries of the European Union, the European Economic Area, or Switzerland. Nor do they apply to persons who have a temporary or permanent residence permit in one of these countries. Moreover, FAQ stated that banks can continue to provide services to holders of long‑term national visas of type D who lawfully reside in one of the listed countries and have completed the formalities for registration at their place of residence. This encompasses visas issued for study, work, family reunification, as well as visas issued on humanitarian grounds.

In a number of its other clarifications,[39] the European Commission officially confirmed that restrictive measures applied to Russian citizens (introduced initially by Regulation No 833/2014, which has been updated in the following years by a number of other Regulations) apply “by analogy” to citizens of Belarus. To formalize this mirroring, the Council of the EU enacted Council Regulation (EU) 2022/398 and Council Regulation (EU) 2024/1865, which explicitly inserted matching restrictive measures (such as deposit limits, security sale bans, and anti-circumvention provisions) into the text of the regulation concerning Belarus. Similar to the gradual expansion of EU sanctions against Russia, broad sanctions against Belarus, initially adopted in 2006 by Regulation No. 765/2006[40] in response to fraudulent presidential elections and post-election repression, were updated in the following years by a number of other Regulations, adding after February 2022 the words “and the involvement of Belarus in the Russian aggression against Ukraine” in the title.[41] Many provisions regarding restrictive measures applied to citizens of the two countries are identical, in particular as regards the area of finance and banking.

The European Commission’s FAQ of March 2026 have not only failed so far to produce any substantial improvement in the situation of exiled Belarusians but have also provided a basis for further violations of their rights. Answering the question “When a new payment instrument is issued under the exception referred to in [paragraph] 5b(3) [of the Regulation introducing the 19th package of sanctions], must a customer’s residence permit be valid for the entire validity period of the [financial] instrument, or is it sufficient for the residence permit to be valid on the day the new instrument is issued?”, the FAQ stated that the residence permit must be valid for the entire validity of the instrument (Q. 8). This caused a situation when many banks have started to obstruct customers’ access to their services and close accounts when a person’s residence permit had expired and s/he had submitted a timely application for a new permit and is waiting for a decision by the authorities – be it on the grounds of work, study, family reunification, or international protection.

According to domestic legislation, a person is considered legally residing in the country during a process of review of her/his application for residence.[ii] However, banks rely not on the national law, but on the FAQ issued by the European Commission, and require a valid residence permit to provide services to Belarusian citizens. Given notoriously very long (and growing) duration of the process of review of residence permit applications in Poland which often extends now to two-three years, thousands of exiled Belarusians have found themselves after the introduction of the 19th sanctions package suddenly deprived of access to financial services. Similar situation has developed in other countries such as Italy and Portugal, where the process of review of applications for residence permit takes a long time. The situation is truly catastrophic, including the inability to receive salary, pay for rent and other basic needs, apply for mortgage, etc.

Finally, a further reason for the mass blocking of bank accounts may lie in banks’ reluctance to incur the costs of “manual” verification of individual customers. This rationale was provided by the German financial institution Scalable Capital, which has blocked accounts on a large scale. Scalable Capital explained that it takes into account country‑specific risk profiles, and, where the costs of manual monitoring of transactions are no longer covered by the standard terms of service, it may terminate the contractual relationships.[42] In this regard, the German national regulator, the Bundesbank, stated in a response to one of Scalable Capital’s clients that European sanctions do not prohibit investment companies from serving Russian (and Belarus) citizens residing in Europe. Moreover, Russian and Belarus citizens holding European residence permits are expressly exempt from the EU restrictions. The regulator therefore concluded that Scalable Capital’s actions were most likely “the result of internal corporate risk management.”[43]

The updated clarifications issued by the European Commission in March 2026 do not address the problems outlined in the present section. Consequently, more unequivocal clarifications from EU institutions and national authorities regarding which documents should be accepted as confirmation of a legal residence (including an explanation of legality of person’s stay during the period of review of an application for residence permit after the previous one has expired, verified by a document from authorities confirming that the review is ongoing), paired with the introduction of amendments to the FAQ concerning the interpretation of the notion of “valid residence permit” are both necessary and urgent in order to guarantee Belarusian exiles’ access to banking services. In parallel, a more active stance on the part of national authorities is required to enforce the non-discrimination principle in the financial sphere.

Recommendations

To inter-governmental organisations:

With regard to the abuse of anti-money laundering / countering the financing of terrorism frameworks:

  • to EU institutions, CoE bodies and OSCE bodies: recognise that requirements for compliance with Financial Action Task Force Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) frameworks may be misused as a tool for TNR and support the development of safeguards to prevent such manipulation by the Lukashenka regime and other repressive regimes;
  • to EU financial regulators: to develop victim-centred redress mechanisms to remedy financial manipulation and long-term harm, including public correction mechanisms;
  • to the AMLA: to develop safeguards to prevent such manipulation, including by applying by financial institutions of individual pre-freeze verifications, appropriate screening, and data protection measures;
  • to the Financial Action Task Force (FATF) and the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL): to treat the misuse of FATF recommendations and anti-money laundering and counter-terrorist financing methods for the purpose of TNR as grounds for finding a state non-compliant with these recommendations and for subjecting it to grey-listing.

With regard to the impact of the cessation of consular services on access to banking services:

  • to the European Commission and EU member states: to establish mechanisms ensuring guaranteed access to basic banking services for individuals credibly at risk of TNR and provide emergency financial continuity or liquidity mechanisms where repression results in sudden asset freezes;
  • to national financial regulators: to instruct banks to accept the foreigner’s travel document as a sufficient ID and to expand the list of documents confirming the legality of stay of a foreigner in the territory of an EU member state as to include all relevant documents issued by the authorities of the host country.

With regard to discrimination based on the principle of belonging to the Belarusian nationality:

  • to the FATF: to develop a recommendation with regard to application by financial institutions of EU sanctions against Russia and Belarus and to instruct banks to accept all relevant documents recognised by the EU and national authorities as confirmation of legal residence sufficient for continued provision of financial services, including national visa D, temporary and permanent residence permits, foreigner’s travel document, and an official confirmation from competent authorities of the ongoing review of an application for resident permit;
  • to the European Commission: amend the FAQ clarifications concerning Article 5b(2) of Regulation (EU) No 833/2014 to explain that the definition of “valid residence permit” should be interpreted more widely and include a period of residence permit application consideration, confirmed by a document issued by competent authorities.

To states:

With regard to the abuse of anti-money laundering / countering the financing of terrorism frameworks:

  • identify, assess, and mitigate structural vulnerabilities in administrative, legal, and financial systems that may be exploited for TNR for blocking access to financial services;
  • develop comprehensive national strategies for tackling TNR, including financial TNR, grounded in a consolidated approach that combines the protection of human rights of those targeted by repression with the safeguarding of state sovereignty;
  • designate national contact points on TNR tasked with coordinating between relevant authorities at all levels and with TNR contact points in other states;
  • produce and distribute clear guidelines to relevant agencies and services on the process of handling reports of TNR and TNR-related human rights violations and providing protection to its targets, including in the cases of financial TNR;
  • ensure increased coordination between national financial regulators, entities and relevant supervisory authorities with the relevant EU bodies addressing TNR;
  • ensure that law enforcement bodies and judiciaries cooperate with financial regulators to help prevent and address abuses of financial systems and travel databases used to facilitate TNR;
  • provide guidance to financial institutions, ensure that national financial regulators take into consideration possible abuse of AML/CFT frameworks by repressive states, issue guidance for banks to eliminate their over-compliance with FATF standards and enforce the principle of individual assessment, and have the mandate to share the data available to them with law enforcement and judiciaries, and establish an effective national complaint and review mechanism;
  • call on financial intelligence units to identify and systematically analyse TNR-linked financial patterns and report relevant findings to national and EU TNR coordination bodies;
  • ensure specialised training for law-enforcement, judicial, financial and cybersecurity authorities on identifying TNR-linked financial patterns, including the misuse of FATF, Interpol and travel database tools;
  • establish clear legal liability for individuals and entities who knowingly facilitate or profit from acts of TNR on behalf of foreign states.

With regard to the impact of the cessation of consular services on access to banking services:

  • issue the foreigner’s travel document to Belarusians who do not possess a valid national passport, and extend the validity period of such a document to several years;
  • ensure that national financial regulators instruct banks to accept the foreigner’s travel document as an identity document and expand the list of documents confirming the legality of stay of a foreigner in the territory of an EU member state.

With regard to discrimination based on the principle of belonging to the Belarusian nationality

  • issue a clarification to banks listing all documents issued by national authorities that should be accepted as confirmation of a legal residence, including a foreigner’s travel document and a confirmation of an ongoing review of an application for residence permit;
  • develop guidelines on the application of the principle of non-discrimination in the financial sphere for banks, the prosecutor’s office and the courts;
  • take effective measures for a timely review of applications for residence permit, which will help addressing the problem of blocking access to financial services by banks in situations when the person legally stays in the country while her/his application is being reviewed but does not have a valid residence permit.

Endnotes

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02.09.2026