Belarus
Wyoming
A Belarusian founder is often told two opposite things: that a US company is closed to them, or that it is open like anywhere else. Neither is accurate.
The law is more open than expected. The banks are more closed than the law. And Belarus taxes what the company pays you, whatever Wyoming charges.
This page takes those three layers in order, from the texts. It suggests no way around any of them.
The short answer, layer by layer
| Layer | Who decides | Position on 5 October 2026 |
|---|---|---|
| Owning the LLC | Wyoming statute | No nationality or residence condition |
| Being served by a US agent | OFAC | No services ban for Belarus. Listed persons are blocked |
| State dissolution over ownership | Wyoming, by reference to a federal list | Belarus is not on the list |
| Bank account | Each provider's own policy | Mercury, Relay and Wise list Belarus |
| Tax at home | Tax Code of Belarus | Worldwide income of a tax resident |
| Moving money out | Currency law and the National Bank | Allowed, with a registration duty |
The formation itself is ordinary: $100 to the state, a registered agent, then $60 a year. The steps are in forming a Wyoming LLC from abroad and the budget in Wyoming LLC cost.
US sanctions on Belarus: named persons, not a country ban
The Belarus program rests on two executive orders, 13405 of 2006 and 14038 of 2021, and on the regulations at 31 C.F.R. part 548. It works by designation.
- Who is blocked: persons on OFAC's SDN list, and entities owned 50% or more by them.
- Who is not: OFAC's FAQ 917 says that naming a sector "does not automatically block all persons operating in that sector".
- What follows for you: an ordinary Belarusian citizen or resident who is not listed, and not owned or controlled by someone listed, is not a blocked person.
The program has moved in 2026, and in the direction of easing.
- 19 Jun 2006Executive Order 13405, first blocking authority
- 9 Aug 2021Executive Order 14038 widens the grounds
- 17 Dec 2024US confirms partial suspension of the 1973 tax convention
- 26 Mar 2026General License 14 authorizes dealings with Belinvestbank
- Jul to Sep 2026Three rounds of Belarus-related delistings
- 31 Dec 2026Treaty suspension ends unless extended
None of that changes the screening. A US agent or bank still checks every owner against the list, and a match stops the file.
What Belarus is not: the Russian rules
Most confusion comes from applying the Russian regime to Belarus. They are separate programs with different mechanics.
| Person living in Russia | Person living in Belarus | |
|---|---|---|
| OFAC ban on formation, agent and address services | Yes, since 7 June 2022 | None found on the Belarus program page |
| Country on the 15 C.F.R. 791.4(a) list | Yes | No |
| Wyoming's 2025 dissolution ground | Reach unsettled for private owners | Does not name Belarus |
| Tax convention with the US | Suspended on both sides | In force, one subparagraph suspended |
Three cautions keep this table from being read too generously.
- Residence travels with you. A Belarusian citizen who ordinarily lives in Russia falls under the Russian services ban, because that test is residence, not passport.
- The adversary list can change overnight. Section 791.4(b) lets the Secretary of Commerce revise it with immediate effect on publication.
- Absence is not a ruling. We found no services determination for Belarus. That is a reading of OFAC's pages on one day, not an OFAC statement.
The Russian side and the dissolution ground are set out in Wyoming LLC for non-residents.
Where the plan stops: the provider lists
Wyoming does not decide who gets an account. Each provider publishes a list of countries it will not serve, and Belarus is on the three that matter most to a solo founder.
| Provider | Belarus | The test applied | Read |
|---|---|---|---|
| Mercury | Listed | Where the founder lives | Page edited 30 Sep 2026, via our banking guide |
| Relay | Listed | Citizenship or residency of any owner | Reopened 5 Oct 2026 |
| Wise | Listed | Where the user is | Reopened 5 Oct 2026 |
| Payoneer | Not confirmed | Not read | Press reports only of account closures from 11 Sep 2026 |
| Stripe | Not confirmed | Not read | No Stripe page naming Belarus was found |
These are company policies, not sanctions law. They did not follow the 2026 easing, and nothing obliges them to.
The test matters more than the list. Mercury looks at residence, so a Belarusian citizen living elsewhere "may still be eligible, pending application review". Relay also looks at the passport, so the same person is refused there unless its partner bank grants an exception.
The full comparison, with the address rules, is in Wyoming LLC bank account for non-residents.
Resident of Belarus, or Belarusian abroad
Almost everything on this page turns on where you live, and Belarus itself uses two different tests for that.
| Test | Source | You are a resident if |
|---|---|---|
| Tax | Tax Code, Article 17 | You were physically in Belarus more than 183 days in the calendar year |
| Currency | Law No. 226-Z, Article 1 | You are a citizen, unless you hold a foreign permanent residence document and spent 183 days or less in Belarus |
A citizen who has left can therefore stop being a tax resident and remain a currency resident, if the foreign permit is temporary. Check both.
| Your situation | Banking | Belarusian tax on the LLC's payouts |
|---|---|---|
| Living in Belarus | Closed at Mercury, Relay and Wise | Yes |
| Citizen living abroad, proof of address there | Mercury's test may be met. Relay's is not | Only while still a tax resident |
| Citizen living in Russia | Russian rules apply first | Follows the 183 day count |
Proof of address has to be true. Misstating where you live to a bank is the one error that cannot be repaired, and it is not a route this page offers.
Belarusian tax: no CFC regime, but two rules that do similar work
The sources diverge here. Some guides state that Belarus has no controlled foreign company rules. Others leave the point open.
We read the consolidated Tax Code, as amended to 30 December 2025. It contains no controlled foreign company regime: the word "controlled" appears only for controlled debt and controlled transactions. Undistributed profit of a foreign company is not attributed to its Belarusian owner.
That is not the same as no exposure. Two provisions reach a company run from Minsk.
- Place of management (Article 16). A company sits where it is registered. If it is absent or inactive there, its seat becomes where its governing body, its executive, or its key decisions and books are.
- What that triggers (Article 15). A company seated in Belarus is a Belarusian tax resident, taxed on worldwide income. Profits tax is 20%.
- Permanent establishment (Article 180). A person in Belarus who acts for a foreign company with authority to conclude its contracts creates a taxable presence.
A Wyoming LLC whose only US footprint is a registered agent, and whose single member does all the work from Belarus, should take this seriously. How the tax authority applies it to such a company is a question for a Belarusian adviser.
What you pay on money the LLC sends you
- 1Were you in Belarus more than 183 days this year?If yes, you are a tax resident and foreign income is taxable
- 2The LLC pays youDividends from a foreign organization are foreign source income
- 3Declare by 31 MarchThe tax office issues a notice by 30 April
- 4Pay by 1 June13%, and 25% on dividends above BYN 350,000 in the year
- 5Credit foreign tax actually paidWith documents, and not for income from listed offshore zones
One point is not settled by the texts we read: whether Belarus treats a payout from a US LLC, which the IRS disregards, as a dividend or as another kind of income. The rate band can depend on it.
The tax convention, and a date to watch
The 1973 convention between the United States and the USSR still applies to Belarus. One provision does not.
- What is suspended: Article III, paragraph 1, subparagraph (g).
- By whom: both governments, by mutual agreement, after Belarus asked on 21 March 2024.
- From when: 17 December 2024.
- Until when: 31 December 2026, "or earlier if mutually determined".
Where the accounts differ. Some guides describe this as Belarus suspending the dividend and interest articles. The IRS announcement and the Treasury release name one subparagraph only. In the convention's text, that subparagraph covers interest on credits and loans connected with the financing of trade between the two countries.
The 1973 convention has no article on dividends at all. So US source dividends paid to a resident of Belarus carry the full 30% withholding, with or without the suspension.
For an LLC with no US income, the convention rarely matters. For passive US income it can, and the federal side is in Wyoming LLC taxes for non-residents. Recheck this section in January 2027.
Moving money: the currency rules
Belarus does not forbid a resident from holding a foreign company or a foreign account. Law No. 226-Z sets the frame.
| Question | Rule | Article |
|---|---|---|
| Foreign bank account | Residents may open one "without restrictions" | 17 |
| Transfers to your own foreign account | Free | 17 |
| Paying a foreign company | Allowed by bank transfer to its foreign account | 13 |
| Receiving dividends abroad | Allowed on a foreign account | 17 |
| Currency contracts | Must be registered under National Bank rules | 8 |
| If not registered | The bank may refuse the operation | 22 |
The threshold and the list of operations are set by National Bank Instruction No. 37 of 12 February 2021, read in its consolidated text with the amendments of 14 September 2022 and 20 September 2024.
- Legal entity or sole trader (point 3). A contract with a non-resident is registered from 4,000 base units of obligations, or when the amount is not fixed.
- Individual (point 3). From 2,000 base units, or when the amount is not fixed.
- A capital contribution is on the list. Point 3 names a cash contribution by a resident to the charter capital of a non-resident company being created abroad, and any later cash contribution. A Wyoming LLC is such a company.
- Conversion (point 4). The amount is converted at the base unit and the official exchange rate in force on the date of the contract.
- Timing (point 7). Registration comes before any step that performs the contract, or within seven working days after money arrives under it.
One limit applies to all of this.
- Restrictions can return. Article 7 allows bans, caps or special permits for up to one year if financial stability is threatened.
There is also a practical obstacle the law does not show. A transfer has to be accepted by the bank at each end, and US banks may still not deal with blocked Belarusian banks.
Before you pay for a filing
- Screen yourself. Confirm that neither you nor any co-owner appears on the SDN list.
- Establish where you live, for both Belarusian tests, with documents.
- Read the provider's country page on the day, against your residence and your passport.
- Get a written answer on the account before forming. A company without a bank is a yearly cost.
- Ask a Belarusian adviser about the management test and the registration duty.
- Plan the US filing. Form 5472 is due each year, with a $25,000 penalty if missed.
The bottom line
For a Belarusian founder, the legal answer is yes. Wyoming sets no nationality test, OFAC's Belarus program blocks named persons instead of a population, and Belarus is not on the list behind Wyoming's dissolution ground.
The practical answer depends on residence. From inside Belarus, the main providers are closed, and that is where the plan usually ends. From abroad, with real proof of address, it becomes an ordinary application at providers that test residence.
Either way, Belarus taxes its residents on what the company pays out. If the banking question has a clear answer in your case, you can see the Wyoming LLC formation service or talk to a specialist first.
Frequently asked questions
Can a Belarusian citizen own a Wyoming LLC?
Yes. Wyoming's statute sets no citizenship or residence condition for members, and US sanctions on Belarus block designated persons and the entities they own, not Belarusian nationals in general.
Is Belarus under the same US services ban as Russia?
No equivalent was found. The OFAC determination that bars formation, registered agent and address services covers persons located in Russia. The Belarus program page lists no such determination as of 5 October 2026.
Can Wyoming dissolve my LLC because I am Belarusian?
The 2025 ground refers to the foreign adversaries listed in 15 C.F.R. 791.4(a). Belarus is not one of the six entries. That list can be revised without notice, so check it again before you file.
Can I open a Mercury, Relay or Wise account from Belarus?
Not according to their published lists. All three name Belarus. Mercury applies its list to where you live, Relay to citizenship or residency, and Wise to where the user is.
Does it help if I live outside Belarus?
It can. Mercury's rule is based on residence, so a Belarusian citizen living elsewhere may be eligible after review. Relay refuses on citizenship as well. You will be asked for proof of address, and it has to be accurate.
Does Belarus have controlled foreign company rules?
The Tax Code as amended to 30 December 2025 contains none. It does treat a company managed from Belarus as resident where it is absent or inactive at its registered seat, and it taxes residents on payouts received from abroad.
How much tax does Belarus charge on money from my LLC?
A tax resident pays 13% on foreign source income, and 25% on dividends above BYN 350,000 in a year. The declaration is due by 31 March and the tax by 1 June, with a credit for foreign tax actually paid.
Is there a tax treaty between the United States and Belarus?
The 1973 convention with the USSR still applies to Belarus. One subparagraph of Article III, on interest from trade financing credits, is suspended by mutual agreement from 17 December 2024 until 31 December 2026, unless both governments end it earlier. The convention has no dividend article, so US source dividends are withheld at 30%.
Sources
- OFAC, Belarus Sanctions program page: Executive Orders 13405 and 14038, the two general licenses in force (GL 12 and GL 14 of 26 March 2026) and the 2026 delistings, with no services determination listed
- 15 C.F.R. 791.4(a): the six foreign adversaries that Wyoming's dissolution ground points to, a list on which Belarus does not appear
- IRS Announcement 2025-5: Article III, paragraph 1, subparagraph (g) of the 1973 US and USSR tax convention suspended for Belarus from 17 December 2024 until 31 December 2026
- Tax Code of the Republic of Belarus, Special Part, as amended to 30 December 2025: Articles 180, 196, 198, 214, 222 and 224 on worldwide income, the 13% and 25% rates, the 31 March declaration and the foreign tax credit
- Law of the Republic of Belarus No. 226-Z on currency regulation and currency control, as amended to 9 December 2025: the currency resident test, foreign accounts and the duty to register currency contracts
- National Bank of Belarus, Instruction No. 37 of 12 February 2021 on the registration of currency contracts by residents, consolidated text with the amendments of 2022 and 2024: thresholds of 2,000 and 4,000 base units and the list of operations (point 3), conversion (point 4) and timing (point 7)
Official, read on 5 October 2026: the OFAC Belarus program page, General License 14 and the Belarus FAQ topic page; 15 C.F.R. 791.4 in the eCFR version of 1 September 2026; IRS Announcement 2025-5 and the Treasury press release of 17 December 2024; the text of the 1973 convention as published by the IRS; the consolidated Tax Code of Belarus (General Part, Articles 15 to 17, and Special Part) as amended by Law No. 127-Z of 30 December 2025; Law No. 226-Z on currency regulation as amended by Law No. 110-Z of 9 December 2025; National Bank Instruction No. 37 of 12 February 2021 on the registration of currency contracts, in the consolidated text published on the national legal portal with the amendments of 2022 and 2024; the Relay and Wise country pages. Taken from our banking guide and not reopened that day: Mercury's list, whose page was edited on 30 September 2026. Not read on any primary source, and labelled as such in the text: the Belarusian act suspending the convention on its side; Payoneer's and Stripe's position on Belarus; and how the Belarusian tax authority classifies payouts from a US LLC. Sanctions lists, provider lists and the treaty suspension all carry dates and can change, the last one on 31 December 2026. Statements about Belarusian law come from the legal texts, not from a Belarusian adviser, and need one before you act. This is not legal or tax advice.