On February 24, 2022, each of the three Belgian Regions (the Flemish, Walloon and Brussels Regions) announced that all export licenses issued by their services with Russia as destination country or country of end-use will be temporarily suspended. The suspension will be evaluated on a day-to-day basis.
The Flemish Strategic Goods Control Unit, which is responsible for issuing licenses for the export of military and dual-use items in the Flemish Region, indicated that for transactions that are not subject to export licenses, it requests increased vigilance. The Flemish Strategic Goods Control Unit indicates that on the basis of Article 4 of the EU Dual Use Regulation 821/2021 read together with the current sanctions against Russia (Regulation 833/2014, as amended) each individual export to Russia which potentially has an end use in defence related production, development or maintenance is subject to a catch-all license requirement, and that such transactions cannot occur without a license from the Flemish Strategic Goods Control Unit.
It is expected that the EU will introduce further sanctions in relation to the export of dual use or dual use related products to Russia.
Press release of the Flemish Strategic Goods Control Unit is available online (in Dutch): https://www.fdfa.be/nl/update-%E2%80%93-escalatie-conflict-oekra%C3%AFne-en-sancties-rusland.
