The European Union has adopted a series of financial restrictive measures against the persons and entities involved in actions threatening the integrity and sovereignty of Ukraine.<\/p>\n
In a circular letter published on 1 March 2022, the Commission de Surveillance du Secteur Financier<\/em> (\u201cCSSF\u201d) reminded that European regulations are binding in their entirety and directly applicable in national law and that professionals of the financial sector, including banking institutions, must comply with them while putting in place the necessary controls and measures.<\/p>\n Before looking at the possible sanctions for non-compliance with these new measures, we will first summarize the financial restrictive measures in question.<\/p>\n All of these EU financial restrictive measures can be classified into 3 broad categories:<\/p>\n Regulation (EU) N\u00b0269\/2014<\/strong> of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine has been amended to add a number of individuals to the list in Annex I, including:<\/p>\n \u00a0<\/strong>Towards Russia<\/em><\/p>\n Regulation (EU) No 33\/20148<\/strong> has been amended[7]<\/a>[8]<\/a> by imposing new restrictive measures prohibiting the financing of Russia, its government and its central bank, including a prohibition on transactions related to the management of the reserves as well as the assets of the Central Bank of Russia, including transactions with any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Russia.<\/p>\n \u00a0<\/strong>Towards the Ukrainian oblasts of Donetsk and Luhansk<\/em><\/p>\n Regulation (EU) 2022\/263<\/strong> published on 23 February 2022[9]<\/a> establishes \u00a0new sanctions regime imposing restrictions on economic relations with the Ukrainian oblasts of Donetsk and Luhansk not controlled by the Ukrainian government.<\/p>\n Towards Belarus<\/em><\/p>\n Regulation (EU) 2022\/355<\/strong>[10]<\/a> published on 2 March 2022 establishes a new regime of individual and economic sanctions extended to Belarus.<\/p>\nWith regard to the financial restrictive measures<\/strong><\/h2>\n
Extension of the assets freeze<\/strong><\/h3>\n
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Prohibition of financing<\/strong><\/h3>\n
Prohibition to provide specialised financial messaging services<\/strong><\/h3>\n
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