On 23 July 2026, the EU adopted its 21^st package of sanctions against Russia.

Please find below details of the 21^st package of restrictive measures imposed In light of the continuing war in Ukraine. These measures include:

• Major expansion of designated persons and entities: The package adds 218 new sanctions listings (48 individuals and 170 entities), making it the largest round of listings in four years.
• Increased focus on financial institutions: The EU imposed asset freezes and funding prohibitions on 94 banks and major financial institutions and extended transaction restrictions to 33 additional Russian financial institutions.
• Crypto-asset risks have become a major enforcement priority: The EU extended restrictions to 14 crypto-service providers and created a mechanism for broader bans on crypto providers that facilitate sanctions evasion.
• Focus on sanctions circumvention through third countries: The package specifically targets entities and institutions in jurisdictions where authorities believe there is circumvention of sanctions. 
• The sanctions package continues targeting networks supporting Russia's military-industrial sector, energy sector and shadow fleet. Many sanctioned entities operate through complex ownership structures and intermediaries.
• Property and corporate transaction risks: The package significantly expands sanctions on oil traders, refineries, shipping companies, military-industrial firms, logistics service providers.
• Asset freeze obligations: The substantial increase in designations raises the risk of inadvertent breaches.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Council website, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found,
• The EU Sanctions Helpdesk website, a platform set up to support small and medium-sized enterprises to comply with EU sanctions,
• The Central Bank of Ireland
• Department of Foreign Affairs

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. All legal and natural persons are bound by the obligations in the sanctions and the Law Society monitors compliance with same as part of its supervisory process.

From January to March 2025 there have been further restrictive measures against Russia and Belarus in relation to the conflict in Ukraine. 

• View the sanctions

The European Commission’s 24 June 2024 Press Release on the 14^th Package can be accessed by visiting the European Commission Website.

Please find below details of the 13^th package of restrictive measures imposed In light of the continuing war in Ukraine.

This is an unprecedented package of 194 individual designations, including 106 individuals and 88 entities. With it, the EU exceeds the threshold of 2000 listings. In particular:

• Targeting Russia's military and defence sector: the new listings include more than 140 companies and individualsfrom the Russian military-industrial complex, which among other things manufacture missiles, drones, anti-aircraft missile system, military vehicles, high-tech components for weapons, and other military equipment.
• Sending a strong signal against Russia's war effort partners: the new listings target 10 Russian companies and individualsinvolved in the shipping of Democratic People's Republic of Korea (DPRK) armaments to Russia. They also target the Defence Minister of the DPRK, as well as several Belarusian companies and individuals providing support to the Russian armed forces.
• Fighting circumvention: the new listings include a Russian logistics company and its director involved in parallel imports of prohibited goods to Russia, and a third Russian actor involved in another procurement scheme.
• Strengthening EU action against Russia's temporary occupation and illegal annexation of areas of Ukraine:the new listings include six judges and 10 officials in the occupied territories of Ukraine.
• Sanctioning violations of children rights:The new listings also include 15 individuals and 2 entities involved in the forced transfer and in the deportation and the military indoctrination of Ukrainian children, including in Belarus.

The Department of Finance asks that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Councilwebsite, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The European Commissionwebsite, from which Frequency Asked Question documents are available
• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

Please do not hesitate to get in touch should you have any queries, contact sanctions@finance.gov.ie

Please find below details of the 12^th package of restrictive measures imposed In light of the continuing war in Ukraine. These measures include:

• Additional listing of over 140 individuals and entities to the sanctions list.
• A ban on direct or indirect import, purchase or transfer of diamonds from Russia.
• A direct ban applies to non-industrial natural and synthetic diamonds.
• Introduction of a no Russia clause which prohibits re-exportation to Russia of particularly sensitive goods and technology,including Russian military systems.
• Further circumvention measures relating to dual use goods and technologies, including extending the transit ban to all battlefield goods.
• Exceptions were introduced for personal use items.
• A ban on Russian nationals from holding any posts on governing bodies.
• Tighter compliance rules have been introduce to clamp down on circumvention to support the implementation of the oil price cap.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Councilwebsite, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The European Commissionwebsite, from which Frequency Asked Question documents are available
• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

Please find below details of the 10^th package of restrictive measures imposed In light of the continuing war in Ukraine. These measures include:

• The introduction of a requirement for all natural and legal persons, entities and bodies to report to both the EU Commission and their relevant National Competent Authorities information on any assets and reserves relating to the Central Bank of Russia. All other frozen assets or reserves must be reported to the relevant National Competent Authorities only;
• An additional 87 individuals and 130 entities have been added to the list of those subject to an asset freeze and travel ban;
• An extension of the current broadcast ban against certain Russian outlets;
• A ban on Russian nationals or persons residing in Russia from sitting on the boards of EU critical infrastructure companies;
• A ban on the provision of gas storage to Russian nationals, those residing in Russia or Russian entities;
• A new reporting requirement for unscheduled flights that have been undertaken, if that flight is suspected of being used to circumvent the current Russian travel ban;
• A ban on the transit of dual-use goods through Russia;
• New classes of goods have been added to the list of those subject to an import or export ban; and
• An exemption has been provided to allow the release of goods that had previously been submitted to EU customs authorities but subsequently found them inadvertently blocked following the introduction of sanctions.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Council website, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The European Commission website, from which Frequency Asked Question documents are available
• The Central Bank of Ireland
• D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

It is also important to note that at its plenary last week, the FATF made a decision to suspend membership of the Russian Federation. A public statement was issued, and can be found here.

Please find below details of the 9th package of EU sanctions imposed in relation to Russia’s unprovoked and unjustified military aggression against Ukraine. These measures include:

• An additional 141 persons and 49 entitieshave been added to the list of those subject to asset freezes and travel bans. This brings the total to 1,382 individuals and 167 entities targeted through the Russian sanctions list.
• All financial transactions with the Russian Regional Development Bank by EU citizens and entitiesare banned. Dalnevostochny Bank and Credit Bank of Moscow are now subject to an asset freeze.
• Additional goods and services have been restricted such as chemicals, riot control agents, electronic components found in Russian weapon systems, UAV/drone components and low-tech goods (generators, laptops, hard-drives). Also, certain goods and services for the space and aviation industries, such as airplane engines and their parts, can longer be provided to Russia, this includes engines utilized in unmanned aerial vehicles.
• The ban on providing services to Russia is extended to include advertising, product testing and technical inspection services. The current ban for EU citizens and entities investing in certain sectors is now extended to include the Russian mining sector. These sectors are being targeted in order to hinder the economic activity of Russia which is financially sustaining its invasion of Ukraine.
• NTV/NTV Mir, Rossiya 1, REN TV and Pervyi Kanal will lose their licenses to broadcast in the EU as of 16 December 2022. They will, however, be able to continue other activities such as research and interviews, which are protected by the Charter of Fundamental Rights.
• The current ban on EU nationals sitting on the boards of Russian companies is extended to include all Russian State-owned companies; at the same time, Russians (nationals and residents) are prohibited from holding roles in EU companies which manage or own critical infrastructure. 
• New measures have been introduced to ensure there is alignment on the reporting obligations of all credit institutions across all Member States.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Councilwebsite, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The European Commissionwebsite, from which Frequency Asked Question documents are available
• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

Please find below details of the most recent measures imposed in light of the escalating war and illegal annexations in Ukraine. These measures include:

• Extending the list of restricted items which might contribute to the Russian Federation’s military and technological enhancement or to the development of its defence and security sector, by including in that list certain chemical substances, nerve agents and goods which have no practical use other than for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment, or which could be used for those purposes.
• Prohibiting the sale, supply, transfer or export of firearms, their parts and essential components and ammunition
• Extending the import ban on steel products that either originate in the Russian Federation or have been exported from it
• Applying an import ban on wood pulp and paper, certain elements used in the jewellery industry such as stones and precious metals, certain machinery and chemical items, cigarettes, plastics and finished chemical products such as cosmetics. This also includes items which could contribute to the enhancement of Russian industrial capacities and restrictions are imposed on the sale, supply, transfer or export of additional goods used in the aviation sector.
• introducing an exemption from the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries of crude oil or petroleum products which originate in or are exported from Russia, purchased at or below a pre-established price cap agreed by the Price Cap Coalition.
• Expanding the prohibition to engage in any transaction with certain Russian State-owned or State-controlled legal persons, entities or bodies by including a ban on EU nationals to hold any posts on the governing bodies of those legal persons, entities or bodies.
• Applying a transaction ban on the Russian Maritime Register of Shipping
• Extending the port access and lock ban in the territory of the EU to vessels certified by the Russian Maritime Register of Shipping.
• Removing the threshold for the existing prohibition on the provision of crypto-asset wallet, account or custody services to Russian persons and residents, thereby banning the provision of such services regardless of the total value of such crypto-assets.
• Extending the existing prohibition on the provision of certain services to the Russian Federation by banning the provision of architectural and engineering services as well as of IT consultancy services and legal advisory services
• Adding 30 persons and seven entities to the list of those subject to a travel ban and asset freeze.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Councilwebsite, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The European Commissionwebsite, from which Frequency Asked Question documents are available
• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

On 21 July, the European Union published a new set of restrictive measures in relation to Russian actions in Ukraine. Measures Include:

• The current packages of sanctions have been extended for an additional 6 months, until the end of January 2023;
• The import of Russian origin gold is prohibited from 22^nd July 2022 onwards;
• An additional 51 items have been added to the export control list, mostly from the industrial and advanced technology sectors;
• An additional 48 individuals and 9 entities are subject to an asset freeze, including Sberbank and Credit Bank of Moscow (which are already removed from Swift messaging system;
• The acceptance of deposits of €100,000 from any Russia national/resident, or Russian/Russian resident controlled (50% or more) entity or body from anywhere outside the EU, is now prohibited.
• Prior authorisation required for accepting deposits needed when trading non-prohibited items between the EU and Russia.
• Clarification that Russian ships cannot dock at canal locks in order to circumvent the ban on entering EU ports;

In addition to this package, new restrictive measures have also been introduced against military forces that have been aiding (directly and indirectly) the military actions of Russia in Ukraine. These measures add 6 Syrian individuals and 1 Syrian entity to an asset freeze and travel ban list.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions.

The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

-        The EU Council website, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found – EU restrictive measures against Russia over Ukraine (since 2014).

-        The European Commission website, from which Frequency Asked Question documents are available – Sanctions adopted following Russia’s military aggression against Ukraine.

-        The Central Bank of Ireland.

-        D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

Please find below details of the most recent measures imposed in relation to Russia’s unprovoked and unjustified military aggression against Ukraine.

This 6th package of measures include:

• A ban on the provision of insurance or reinsurance to the maritime transport of Russian oil to third countries;
• A ban on providing accounting, auditing, bookkeeping and tax consulting services, business and management consulting and public relations services to Russia;
• A wide variety of chemicals, including items used as precursors to the creation of chemical weapons, will be banned from sale to Russia;
• The import of goods such as wood, rubber, cement, fertilizer and ingredients used to manufacture fertilizer from Russia and Belarus is banned; 
• 65 additional Russian individuals and 18 entities have been made subject to asset freezes and travel bans; 
• 12 Belarusian individuals and 8 entities have been made subject to asset freezes and travel bans;
• Removal of banks from SWIFT:
  • 3 Russian banks: Sberbank, Credit Bank of Moscow and JSC Rosselkhozbank are removed from SWIFT;
  • 1 Belarusian bank: Belinvestbank, is removed from SWIFT; 
• 3 additional Russian TV stations are subject to a broadcast ban - Rossiya RTR/RTR Planeta, Russia 24 and TV Centre International; 
• RT and Sputnik will also be subject to an advertising ban; and 
• The list of items banned from import from Russia has been extended, to include certain chemicals that can be used for the manufacture of chemical weapons. 

A general prohibition has been introduced on the import and transport of Russian crude oil and petrol products for all EU Member States. A lead-in period of six months has been provided for crude oil and eight months for petrol products, after which the import of such products will be prohibited. Some MS have received derogations from this measure due to their geographic location or their over-reliance on Russian fuel:

• As landlocked countries, Hungary, Czechia and Slovakia are disproportionately dependent on Russia for crude oil imported by pipeline, therefore these MS are exempted from the import ban until alternative supply lines are sourced;
• If the supply of crude oil by pipeline from Russia to any of the three Member States mentioned above is interrupted, seaborne crude oil from Russia may be imported into that Member State through other Member States;
• Bulgaria can continue to authorise contracts up until 31 December 2024 for seaborne crude oil and petroleum products; and
• Croatia can continue to authorise contracts relating to the import of vacuum gas oil until 31 December 2023.

In relation to the measure regarding trusts and those providing services to them, that was adopted in the last package - following discussions with the EU Commission and discussions amongst Member States, agreement was reached to amend that measure. The position is now that certain types of trust, detailed below, can apply to the competent authorities for a derogation from the sanction. Trusts will have 30 days from today to make such an application. The three Irish competent authorities are the Department of Foreign Affairs, Department of Enterprise, Trade & Employment and the Central Bank of Ireland. Currently, we have no information about which (or if all three) competent authority will be providing the application facility for trusts; nor do we have information about what information a trust will have to provide in order to successfully secure a derogation. The trust types eligible for a derogation are:

• occupational pension schemes; 
• insurance policies; 
• employee share schemes; 
• charities; 
• amateur sports clubs; 
• funds for minors or vulnerable adults. 

In addition, trustees and TCSPs have been given an additional month - to 5 July 2022 - to cease all operations with trusts that remain within the remit of the sanction. 

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Council website, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found – EU restrictive measures against Russia over Ukraine (since 2014).
• The European Commission website, from which Frequency Asked Question documents are available – Sanctions adopted following Russia’s military aggression against Ukraine.
• The Central Bank of Ireland.
• D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page.

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

The European Commission have updated several of their sanctions FAQs recently. Please use the following links to access information on:

• Central Securities Depositories
• Circumvention and due diligence
• Asset freeze and prohibition to make funds and economic resources available
• Deposits
• Public Procurement
• Prohibition to access EU ports and
• Sale of securities.

Please find below details of the most recent measures imposed in relation to Russia’s unprovoked and unjustified military aggression against Ukraine. These measures amend the most recent sanctions package to:

• Provide for derogations for humanitarian purposes; and
• Restrictive measures on two additional businesspeople - Serhiy Vitaliyovich KURCHENKO and Yevgeniy Viktorovich PRIGOZHIN. EU restrictive measures regarding the undermining of the territorial integrity of Ukraine now apply to a total of 1093 persons and 80 entities.now apply to a total of 1093 persons and 80 entities.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Councilwebsite, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

Please find below details of the most recent measures imposed in relation to Russia’s unprovoked and unjustified military aggression against Ukraine. These measures amend the most recent sanctions package to:

• Provide for derogations for humanitarian purposes; and
• Restrictive measures on two additional businesspeople - Serhiy Vitaliyovich KURCHENKO and Yevgeniy Viktorovich PRIGOZHIN. EU restrictive measures regarding the undermining of the territorial integrity of Ukraine now apply to a total of 1093 persons and 80 entities.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Councilwebsite, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

Please find below details of the most recent measures imposed in relation to Russia’s unprovoked and unjustified military aggression against Ukraine. On 8 April 2022, the EU published a further set of measures in relation to Russia and Belarus. These measures are set out in full in the Regulations and include:

• A prohibition on being a beneficiary, acting as a trustee or in similar capacities for Russian persons and entities, as well as a prohibition on providing certain services to trusts has been introduced.
• An import ban on coal from Russia from 10 August 2022;
• A full transaction ban on four key Russian banks. These four banks will now be fully excluded from the EU market. The banks affected are Otkritie, Novikombank, Sovkombank and VTB;
• A ban on any vessel registered under the flag of Russian from accessing EU ports. This includes yachts and recreational craft. Some derogations are granted for the transport of medical, pharmaceutical, agricultural and food products, humanitarian aid, energy and other products as set out in the Regulations;
• A ban on Russian and Belarusian road transport operators traveling the European Union, Switzerland, EEA and western Balkans, limiting their access to key goods;
• Further targeted export bans on items such as quantum computers and advanced semiconductors, sensitive machinery and transportation equipment;
• Specific new import bans on a range of goods as well closing loopholes between Russia and Belarus. This will be achieved by sanctioning certain individuals and entities used to bypass previous sanctions;
• A €10,000 limit on crypto asset transactions;
• Securities in all EU Member State currencies will now be banned from sale to Russia/Belarus and Russian/Belarusian entities;
• A general EU ban on participation of Russian companies accessing public procurement in Member States;
• An exclusion of all financial support at a national and European Union level to Russian public bodies; and
• Listing of an additional 216 individuals who are Russian, members of 'the People’s Council' of the Donetsk and Luhansk breakaway republics as well as 18 new entities. The list also includes Oleg Deripaska and the 2 daughters of Vladimir Putin.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book.

• The EU Councilwebsite, from which the measures agreed at an EU level in response to the crisis in Ukraine can be found
• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page

Please monitor the websites referenced above closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

On 15 March 2022, the EU published a further set of measures in relation to Russia.

The measures that came into force on 15 March include:

• adding another 15 individuals and 9 entities to the list of those subject to asset freezes and travel bans.

The measures that come into force on 16 March include:

• a ban on credit ratings agencies from providing ratings on Russian Federation debt.

• further trade restrictions concerning iron and steel, as well as luxury goods;

• expanding the list of persons connected to Russia’s defense and industrial base, to apply tighter export restrictions on dual-use goods and technology. A total of 81 persons and entities have been added;

• prohibitions on new investments in the Russian energy sector and export restrictions on related equipment, technology and services, with the exception of nuclear industry and energy transport;

• a ban on all transactions with certain State-owned enterprises which are already subject to refinancing restrictions. A total of 13 companies are listed;

• a ban on the provision of insurance and reinsurance to any legal person, entity or body operating in the energy sector in Russia;

• Derogations have been provided for activities necessary for ensuring critical energy supply within the EU, as well as the transport of fossil fuels, in particular coal, oil and natural gas, from or through Russia into the EU; and where humanitarian considerations arise.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The EU Council website, where the measures agreed at an EU level in response to the crisis in Ukraine are outlined
• The Central Bank of Ireland
• D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page.

The most recent measures imposed on the Russian Federation and Belarus in response to the unprovoked and unjustified military aggression against Ukraine.

On 9 March 2022, the EU published a further set of measures. These include:

• Introduction of further restrictions on the export of maritime navigation goods and technology;
• Expansion of the list of legal persons, entities and bodies subject to the prohibitions related to investment services, transferable securities, money market instruments, and loans;
• Further clarification (in respect of previous restrictive measures) that “transferable securities” includes crypto-assets.
• Limiting the financial inflows from Belarus to the Union, by prohibiting the acceptance, from Belarusian nationals or residents, of deposits exceeding certain values; the holding of accounts of Belarusian clients by the Union central securities depositories; and the selling of euro-denominated securities to Belarusian clients;
• Exemptions under the sanctions measures, for Swiss, EU and EEA nationals in Belarus, in that deposits exceeding €100,000 can be accepted from them.
• Introduction of clarifications on the exception for the provision of financing for small and medium-sized enterprises, as well as certain provisions in the Annexes, relating to prohibited goods and technology;
• Adding 146 members of the Russian Federation Council to the sanctions list, as those individuals ratified the government decisions of the ‘Treaty of Friendship, Cooperation and Mutual Assistance’ between Russia and the two break-away regions in Donetsk and Luhansk;
• Adding 14 persons to the sanctions list, as they supported and benefited from the Government of the Russian Federation and/or provided substantial revenue to it; or are associated with listed persons or entities.
• Prohibition on the listing and provision of services, on Union trading venues, in relation to shares of Belarus State-owned entities;
• Prohibition on transactions with the Central Bank of Belarus;
• Restrictions on the provision of specialised financial messaging services (SWIFT) to certain Belarusian credit institutions and their Belarusian subsidiaries. These are:
  • - Belagroprombank
  • - Bank Dabrabyt
  • - Development Bank of the Republic of Belarus'
• Additional obligations on the Network Manager for air traffic management network functions of the single European Sky, particularly that the Manager rejects all flight plans that violate the Regulations;
• Further clarification (in respect of previous restrictive measures) that “transferable securities” includes crypto-assets.

The Department of Finance ask that all entities familiarise themselves with the measures introduced and how they can comply with the sanctions. The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The measures agreed at an EU level are summarised at https://www.consilium.europa.eu/en/policies/sanctions/restrictive-measures-ukraine-crisis/ with a timeline available here. The lists of persons and entities under EU restrictive measures over the territorial integrity of Ukraine are available here.
• The Central Bank of Ireland
• D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page

Please monitor the websites referenced below closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same.

Guidance note on Regulation (EU) No 833/2014 and opportunity to consult on upcoming sanctions guidance

We received a communication from DG FISMA, the Directorate General in the Commission responsible for sanctions. They acknowledged that the swiftly adopted measures pose a significant challenge for economic operators who have to respect these sanctions at very short notice.

In order to facilitate compliance, DG FISMA has confirmed that it will provide guidance on the new sanctions as soon as possible. In the interim, they recommend consulting the Commission Guidance Note on the implementation of certain provisions of Regulation (EU) No 833/2014, in case queries may be answered there.

The European Union sanctions whistleblower tool was rolled out last Friday 4 March 2022, and is accessible via the Commission’s website at https://eusanctions.integrityline.com/. It facilitates the anonymous reporting of possible violations of EU sanctions. It can be used to report past, ongoing or planned sanctions violations, as well as attempts to circumvent EU sanctions.

More details about the tool are available on the European Commission website.

Please find below details of the most recent measures imposed on Belarus in response to its unprovoked and unjustified military aggression against Ukraine:

• An EU travel ban and asset freeze in respect of 22 persons associated with the Belarusian military and Ministry for Defence. These measures are imposed under the existing sanctions regime in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

Please find below details of the most recent measures imposed on the Russian Federation in response to its unprovoked and unjustified military aggression against Ukraine:

• Existing sanctions measures against 7 persons have been extended
• 1 person has been removed from the list

Please monitor the websites referenced below closely in the event that further information is available or further restrictive measures are adopted. It is very important that all supervisors in particular keep up to date on developments and ensure that the obligations arising from the sanctions are communicated appropriately to all obliged entities. All legal and natural persons are bound by the obligations in the sanctions and supervisors need to ensure compliance with same. 

The relevant Statutory Instruments in relation to Sanctions against the Russian Federation, and Belarus for its role in the aggression are, or will shortly be, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The Central Bank of Ireland
• D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page
• The measures agreed at an EU level are also summarised on the EU Council website with a timeline available here. The lists persons and entities under EU restrictive measures over the territorial integrity of Ukraine are available here.

Please find below details of additional measures imposed on the Russian Federation in response to its unprovoked and unjustified military aggression against Ukraine:

• A ban on the sale, supply, transfer or export of coEuro banknotes to Russia or to any natural or legal person, entity or body in Russia is being introduced. This includes the Russian government and the Central Bank of Russia.
• The removal of 7 Russian banks from the SWIFT system with a 10 day lead in time. This includes any entity that the listed banks own 50% or more of. The banks affected are:
• Bank Otkritie
• Novikombank
• Promsvyazbank
• Bank Rossiya
• Sovcombank
• VNESHECONOMBANK (VEB)
• VTB BANK
• A prohibition on investing in, participating or otherwise contributing to projects co-financed by the Russian Direct Investment Fund.
• A prohibition on broadcasting or enabling the broadcast of state-owned media Russia Today or Sputnik in the EU.

The relevant Statutory Instruments are, or will be shortly, available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The Central Bank of Ireland
• D/Foreign Affairs – who also have domestic guidance on the implementation of sanctions at the bottom of that page
• The measures agreed at an EU level are outlined on the Council of the EU website and today’s press release is available here.

Statutory Instruments No 81/2022 and 82/2022 and are available on the Irish Statute Book. Further information on restrictive measures can be viewed also at:

• The Central Bank of Ireland
• D/Foreign Affairs– who also have domestic guidance on the implementation of sanctions at the bottom of that page

A third sanctions package is imminent. As part of this proposed third package, the Commission is asking for:

• The removal of some, as of yet unnamed, banks from the Swift system
• The freezing of the assets of the Russian Central Bank