RuAviation

On September 12, 2025, the US Bureau of Industry and Security (BIS) issued an official authorization letter to Belavia, the national airline of Belarus. This document partially lifted restrictions imposed on the carrier since 2023, while simultaneously introducing new sanctions. Specifically, Belavia is now permitted to maintain and operate eight Boeing aircraft, but is expressly prohibited from using them for flights to Russia and several other countries. The BIS letter marks the first formal document to combine both the easing and tightening of sanctions in this manner.

Previously, the US had restricted Belavia’s access to technical support, spare parts, and financial transactions, resulting in a reduced fleet and lower operational readiness. However, there was no explicit ban on operating Boeing aircraft on routes to Russia. The new BIS letter changes this framework, introducing a specific clause prohibiting flights to Russia using US-manufactured aircraft.

According to the BIS letter, Belavia is authorized to operate eight specific Boeing aircraft, including the 737 MAX 8, 737-3Q8, 737-31S, 737-8ZM, 737-82R, and 737-8K5 models.

All these aircraft have been removed from General Prohibition 10 (GP10), which previously blocked all maintenance and repair activities. Belavia can now legally conduct scheduled and unscheduled inspections, major overhauls, restorations, and procure original spare parts for these aircraft.

The authorization covers the export, re-export, and transfer of equipment, consumables, and components, provided they are intended to maintain the airworthiness of the specified aircraft. Each supply request is reviewed individually to prevent misuse. This enables Belavia to maintain its Boeing fleet in compliance with international safety and operational standards, which is critical for flight safety and schedule reliability.

The list of permitted operations does not include the Boeing 767-8EVBBJ2 (EW001PA), which is used for government purposes. Full restrictions remain in place for this aircraft, highlighting the BIS’s selective approach to different types of operations.

Flight Restrictions to Russia: A New Sanctions Mechanism

For the first time, the BIS letter formalizes a ban on the use of US-manufactured aircraft by Belavia for flights to Russia, as well as to Iran, North Korea, Syria, Cuba, Crimea, the Donetsk People’s Republic (DPR), and the Luhansk People’s Republic (LPR). This restriction, effectively a sanction, applies to all eight authorized Boeing aircraft and is codified under US Export Administration Regulations (EAR), sections 744.7 and 746.8. Exceptions are possible only with a specific BIS license, which is unlikely in practice.

The restrictions apply not only to routes but also to cargo. The use of these aircraft for transporting goods potentially linked to the special military operation in Ukraine is prohibited. Any operations involving Russia are subject to strict BIS oversight and require separate authorization. Until September 12, 2025, restrictions focused on maintenance and supply, not flight routes. The new BIS letter tightens the sanctions regime, further limiting Belavia’s ability to operate its Boeing fleet on eastern routes.

As of 2025, Belavia’s fleet also includes 15 Embraer aircraft: three E195-E2s, seven E195s, and five E175s. The Embraer 195-E2, the largest in the E-Jet family, seats up to 146 passengers and is capable of medium- and long-haul flights with a maximum range of 2,990 miles (4,815 km). The Embraer 195 accommodates about 107 passengers and is designed for medium-haul routes. The Embraer 175 is a regional jet with up to 76 seats, optimized for short- and medium-haul operations.

However, these aircraft offer lower capacity and range compared to Boeing models. In addition to Moscow and St. Petersburg, Belavia serves Sochi, Kazan, Noyabrsk, Kaliningrad, Yekaterinburg and
other Russian cities. With Embraer aircraft, Belavia’s passenger traffic to Russia will decrease significantly compared to operations with higher-capacity Boeing 737s. Under current conditions, the airline urgently needs Russian-built aircraft, such as the MC-21-310, but deliveries are not expected until late 2026, while operational needs are immediate.

In this context, the proposal to transfer S7 Airlines’ A321neo aircraft to Belavia, recently discussed by MelonAero President Oleg Evdokimov with the Russian Aviation website, gains relevance. The editorial team contacted him for comment on the Trump administration’s ban on flights to Russia.

“The BIS documents clarify the specifics of the sanctions and underscore the need for Belavia to seriously consider requesting S7’s A321neo aircraft. Yes, it’s a new type, and yes, it’s challenging, but operating Embraers on Moscow routes is a highly questionable option,” Evdokimov stated.

He noted that replacing Boeing with Embraer in the Russian capital would likely cause significant dissatisfaction due to the E-Jets’ lower capacity and range. This would inevitably impact load factors and the economic viability of flights, potentially reducing traffic flows.

“This approach demonstrates pragmatism but also political ambiguity on the part of the US administration. For Belavia and the Russian market, the economic risks are clear, given the limited ability to use modern Boeings on key routes, which calls into question the effectiveness of further investment in Embraer aircraft as an alternative. The Trump administration’s policy appears to be a compromise between political objectives and technical requirements,” the expert concluded.

The BIS Letter: A Dual Approach to Belarus

The BIS letter of September 12, 2025, illustrates the duality of US policy toward Belarus. On one hand, Belavia is allowed to maintain its Boeing 737 fleet, procure spare parts, and conduct technical maintenance. On the other, a strict ban on using these aircraft for flights to Russia and several other countries reflects the priorities of US foreign policy.

This approach demonstrates a systematic disregard for Belarusian interests, reducing the airline’s operational efficiency and exerting additional pressure on the Belarusian economy. Serious doubts arise regarding the sincerity of statements made by President Trump’s special envoy during his September 11 meeting with Belarusian President Alexander Lukashenko in Minsk.

Artem Kirillov
for RuAviation