Changes to the Russia/Ukraine Regulations as of 3 June 2022

Given the developing situation in Ukraine, Central Bank of Ireland will publish details of new restrictive measures/sanctions that are adopted in this regard, as well as any associated EU Guidance, on this page. All natural and legal persons must comply with EU Regulations relating to financial sanctions as soon as they are adopted. While sanctions are applicable to all natural and legal persons, given the nature of the activities carried out by credit and financial institutions, some additional guidance is provided below for this sector.

The European Commission has a dedicated webpage, entitled Sanctions adopted following Russia’s military aggression against Ukraine , which contains information on the various sanctions adopted, including Frequently Asked Questions. The page is regularly updated. Therefore, natural and legal persons are encouraged to regularly visit this page for the latest information.

The Central Bank of Ireland has issued a Letter to business and professional representative bodies, to provide information and to request that the information be shared, in order to assist their members as they meet their obligations under the EU Financial Sanctions.

Financial Sanctions Letter 16 June 2022 | pdf 497 KB

3 June 2022

On 3 June 2022, the EU adopted a sixth package of sanctions. Briefly, these measures comprises:

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/879)

    This introduces, inter alia, an extension to the prohibition on the provision of specialised financial messaging services (SWIFT) to three additional Russian credit institutions (Sberbank, Credit Bank of Moscow, and Russian Agricultural Bank), an expansion to the list of persons connected to Russia’s defence and industrial base, and an extension of the deadline for the cessation of activities provided for in paragraphs 2 and 3 of Article 5m of Regulation 833/2014, from 10 May 2022 until 5 July 2022.

  • Amendments to existing sanctions regime – Belarus (Sectoral Measures) Regime (Council Implementing Regulation 2022/876 and Council Regulation 2022/877) 

    Council Implementing Regulation 2022/876 adds 12 individuals and 8 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures. Council Regulation 2022/877 expands the list of Belarusian credit institutions and their Belarusian subsidiaries subject to restrictive measures with regard to the provision of specialised financial messaging services (SWIFT).

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Implementing Regulation 2022/878 and Council Regulation 2022/880)

Council Implementing Regulation 2022/878 adds 65 individuals and 18 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures. Council Regulation 2022/880 introduces further derogation options from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities, and clarifies and strengthens the provisions on national penalties for the breach of measures.

Further information and background to these measures can be found on the European Council website and the Department of Foreign Affairs website

21 April 2022

On 21 April 2022, the EU adopted an amendment to existing sanctions regime – Ukraine (Territorial Integrity) Regime, through Council Implementing Regulation 2022/658. This added two individuals to the list of persons, entities and bodies subject to restrictive measures.

20 April 2022

The Central Bank has provided information on how credit institutions should report information regarding deposits by certain persons linked to Russia/Belarus that exceed EUR 100,000.  Please see below under the heading “Reporting by credit institutions of deposits exceeding EUR 100,000”, and the Central Bank’s Sanctions Reporting webpage, which contains the Deposit Prohibition Reporting Form.

8 April 2022

On 8 April 2022, the EU adopted a fifth package of sanctions. Briefly, these measures comprises:

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/576)

    This introduces, inter alia, a prohibition on the award and continued execution of public contracts and concessions with Russian nationals and entities or bodies established in Russia. It also extends the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of the Member States.

  • Amendments to existing sanctions regime – Belarus (Sectoral Measures) Regime (Council Regulation 2022/577) 

    This imposes, inter alia, further restrictive measures prohibiting the sale to Belarus of transferable securities denominated in any official currency of a Member State, and prohibiting the sale, supply, transfer or export to Belarus of banknotes denominated in any official currency of a Member State.

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Regulation 2022/580 and Council Implementing Regulation 2022/581)

    Council Regulation 2022/580 introduces further derogation options from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities. Council Implementing Regulation 2022/581 adds 216 individuals and 18 entities, including four Russian banks, to the list of persons, entities and bodies subject to restrictive measures.

Further information and background to these measures can be found on the Department of Foreign Affairs website.

24 March 2022

The European Commission has set up a dedicated webpage, entitled Sanctions adopted following Russia’s military aggression against Ukraine, which contains information on the various sanctions adopted, including Frequently Asked Questions. The page is regularly updated. Therefore, natural and legal persons are encouraged to regularly visit this page for the latest information, in particular before contacting the Central Bank with queries relating to sanctions adopted in this regard.

15 March 2022

A further set of sanctions measures was adopted on 15 March 2022.  Briefly, these measures comprises:

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Implementing Regulation 2022/427)

    This introduces additional individuals (15) and entities (9) to the list of persons, entities and bodies subject to restrictive measures.

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/428) This introduces, inter alia, new measures to prohibit all transactions with certain Russian state-owned companies, as well as prohibiting the provision of credit rating services and related subscription services to Russian persons or entities. New investments in the Russian energy sector are also prohibited. 

Further information and background to these measures can be found on the Department of Foreign Affairs website.

9 March 2022

A further set of sanctions measures was adopted on 9 March 2022.  Briefly, these measures comprises:

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/394)

    This introduces restrictions with regard to the maritime sector, an extension to the list of persons, entities and bodies subject to subject to the prohibitions related to investment services, transferable securities, money market instruments, and loans, as well as certain clarifications, including in respect of crypto assets.

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Implementing Regulation 2022/396)

    This introduces additional individuals, including members of the Russian Federation Council, to the list of persons, entities and bodies subject to restrictive measures.

  • Amendments to existing sanctions regime – Belarus (Sectoral Measures) Regime (Council Regulation 2022/398) 

    This introduces an extension of financial measures and certain clarifications, including in respect of crypto assets.

Further information and background to these measures can be found on the Department of Foreign Affairs website.

In addition to these new sanctions measures, and more generally, the European Commission launched a whistleblower tool on 4 March. The whistleblower tool is intended to facilitate reporting of possible sanctions violations. Further details on the tool are set out below, under the heading EU sanctions whistleblower tool.

2 March 2022

A fourth set of EU sanctions was adopted on 1 and 2 March 2022.  Briefly, these measures comprises:

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/345 and Council Regulation 2022/350)

    This introduces restrictions with regard to the provision of specialised financial messaging services which are used to exchange financial data to certain Russian credit institutions. The measures also prohibit the sale, supply, transfer or export of euro-denominated banknotes to Russia or to any natural or legal person, entity or body in Russia, including the government and the Central Bank of Russia, or for use in Russia, and prohibit investment in, participation in or other contributions to projects co-financed by the Russian Direct Investment Fund. Certain exceptions and derogations may apply.

    Restrictions are also introduced on the media sector.

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Implementing Regulation 2022/353)        

    This adds additional individuals (22) to the list of persons, entities and bodies subject to restrictive measures.

  • Amendments to existing sanctions regime – Belarus (Sectoral Measures) Regime (Council Regulation 2022/355)

    This introduces further restrictions on trade between the EU and Belarus.        

Further information and background to these measures can be found on the Department of Foreign Affairs website.

28 February 2022

A third round of EU sanctions was adopted on 28 February 2022.  These measures relates to aviation and finance, as well as additional individual listings. Briefly,  these measures comprises:

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/334)

    This introduces measures to prohibit any transactions with the Central Bank of Russia. In addition, it introduces restrictions on the aviation sector. 

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Implementing Regulation 2022/336) This extends listing criteria, to add additional individuals (26) and one entity to the list of persons, entities and bodies subject to restrictive measures.    

Further information and background to these measures can be found on the Department of Foreign Affairs website.

25 February 2022

A second round of EU sanctions was adopted on 25 February. These measures covers the financial sector, the energy and transport sectors, dual-use goods as well as export control and export financing, visa policy, additional listings of Russian individuals and new listing criteria. Briefly, these measures comprises:

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/328)

    This introduces further restrictions related to finance, defence, energy, aviation, and space industry. This expands existing financial restrictions, in particular access by certain Russian entities to EU capital markets; prohibits the listing and provision of services in relation to shares of Russian state-owned entities on EU trading venues; and limits financial inflows from Russia to the EU by prohibiting the acceptance of deposits exceeding certain values from Russian nationals or residents, the holding of accounts of Russian clients by the EU Central Securities Depositories and the selling of euro-denominated securities to Russian clients.

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Regulation 2022/330 and Council Implementing Regulation 2022/332) This extends listing criteria, to add additional individuals to the list of designated persons.

Further information and background to these measures can be found on the Department of Foreign Affairs Restrictive Measures (Sanctions) website.

23 February 2022

The first set of EU sanctions, adopted on 23 February 2022,  comprises targeted restrictive measures on a number of individuals and entities, restrictions on economic relations with the non-government controlled areas of the Donetsk and Luhansk oblasts, and financial restrictions against Russia. Briefly, this package of measures comprises:

  • A new sanctions regime – Ukraine (Donetsk and Luhansk Sectoral Measures) Regime (Council Regulation 2022/263)
    This introduces restrictions on goods originating in the specified territories and on the provision, directly or indirectly, of financing or financial assistance, as well as insurance and reinsurance, related to the import of such goods, with the exception of goods having been granted a certificate of origin by the Government of Ukraine.

  • Amendments to existing sanctions regime – Russia (Sectoral Measures) Regime (Council Regulation 2022/262)
    This introduces a prohibition on the financing of Russia, its government and its Central Bank.

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Implementing Regulation 2022/260 and Council Regulation 2022/259)
    This adds additional individuals (22) and entities (four) to the list of persons, entities and bodies subject to restrictive measures.

  • Amendments to existing sanctions regime – Ukraine (Territorial Integrity) Regime (Council Implementing Regulation 2022/261)
    This adds additional individuals (336) to the list of persons, entities and bodies subject to restrictive measures.

For further information and background to this sanctions package, please see press release, dated 24 February 2022, from the Department of Foreign Affairs, the website of the Department of Finance, and press release, dated 23 February 2022, from the Council of the EU.

The EU sanctions map provides comprehensive details of all EU sanctions regimes and their corresponding legal acts, including those regimes adopted by the UN Security Council and transposed at EU level. All entities dealing with Financial Sanctions should refer to the EU Sanctions Map for guidance.

Financial Sanctions Requirements

There is a legal obligation to comply with EU Council Regulations relating to financial sanctions as soon as they are adopted.  Once a person, entity or body has been sanctioned under EU Financial Sanctions, there is a legal obligation not to transfer funds or make funds or economic resources available, directly or indirectly, to that person, entity or body.  Accounts, funds or other assets belonging to that person, entity or body should be frozen without delay so that they cannot be made available, directly or indirectly, to that sanctioned person, entity or body.

Guidance for Credit and Financial Institutions (Firms)

While sanctions are applicable to all natural and legal persons, given the nature of the activities carried out by Firms, some additional guidance is provided below.

Firms must ensure that they are compliant with financial sanctions. This includes carrying out ongoing monitoring of transactions and customers.  To ensure compliance with EU financial sanctions, it is necessary to monitor the EU Financial Sanctions lists.

What to do if a match or "hit" occurs

In the event that a match or a “hit” occurs against a sanctioned person, entity or body, Firms must immediately freeze the account(s) and/or stop the transaction(s) and report the “hit” to the Central Bank by email to sanctions@centralbank.ie, using the Sanctions Return Form. For further information on sanctions reporting, please visit the Central Bank’s dedicated Sanctions Reporting webpage.

Reporting by credit institutions of deposits exceeding EUR 100,000

Credit institutions are obliged to report deposits exceeding EUR 100 000 that are:

  • held by Russian/Belarusian nationals or natural persons residing in Russia/Belarus, or by legal persons, entities or bodies established in Russia/Belarus. Updates must be provided regarding the amounts of such deposits every 12 months.
  • held by Russian/Belarusian nationals or natural persons residing in Russia/Belarus who have acquired the citizenship of a Member State or residence rights in a Member State through an investor citizenship scheme or an investor residence scheme.

These obligations are subject to certain exemptions as set out in the relevant EU Council Regulations. Reporting of such information must be made to the Central Bank by email to sanctions@centralbank.ie, using the Deposit Prohibition Reporting Form. For further information on Deposit Prohibition reporting, please visit the Central Bank’s Sanctions Reporting webpage

Authorisations/Derogations under Financial Sanctions

In certain specific circumstances (which are set out in the relevant Regulations), a person may be authorised to make a transfer to a sanctioned person, entity or body if a prior authorisation is received or where notification is given to a competent authority in accordance with such Regulation.

Any requests for authorisations or derogations relating to a financial sanction under the relevant Regulations should be directed to the Central Bank by emailing sanctions@centralbank.ie.  Derogation applications should be accompanied by the Central Bank’s Sanctions Derogation Application Form. For further information on derogations, please visit the Central Bank’s dedicated Derogations webpage.

Authorisation/derogation requests relating to other types of sanctions (e.g. dual-use goods / travel restriction) under the relevant Regulations should be directed to the most appropriate competent authority (Department of Foreign Affairs, or the Department of Enterprise, Trade and Employment).

EU sanctions whistleblower tool

If you are aware of possible violations of any EU sanctions, you can bring this to the attention of the European Commission by voluntarily providing information. This information can relate, for example, to facts concerning sanctions violations, their circumstances and the individuals, companies and third countries involved. These can be facts that are not publicly known but are known to you and can cover past, ongoing or planned sanctions violations, as well as attempts to circumvent EU sanctions. View further details on the EU sanctions whistleblower tool.

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