On 20 June 2022, the Central Bank of Ireland ("Central Bank") issued a letter to business and professional representative bodies providing information and requesting that the information be shared, in order to assist their members as they meet their obligations under the EU Financial Sanctions. In particular, attention is drawn to the Central Bank's dedicated Russian / Ukraine Regulations webpage and a related Frequently Asked Questions section.
The letter also sets out key messages to aid individuals and entities understanding of their obligations and their role in the effective implementation of sanctions. Where a business or individual is in possession or control of funds or economic resources of a person / entity that is subject to a financial sanction, that business or individual is legally obliged to: freeze the funds or economic resources; refuse to deal with or release the funds or economic resources to the sanctioned person, unless there is an available exemption and has obtained the required authorisation from the Central Bank; and report the freezing of the funds or economic resources to the Central Bank. A breach or suspected breach of sanctions must be reported to An Garda Síochána.
It follows the Central Bank's previous 7 March 2022 letter to funds service providers on effective management of risks due to the ongoing Russian invasion into Ukraine. For further details, see our prior update CBI Issues Letter on Managing Risk Due to the Russian Invasion into Ukraine.