In the wake of Russia's invasion of the Ukraine early last week, the European Union responded with the adoption of a package of sanctions, most recently, yesterday on 2 March. In this update, we provide clients with a high level guide to the sanctions and reiterate the compliance obligations of regulated financial services firms in respect of sanctions.
Introduction
The past week has seen the adoption of a number of European Union ("EU") sanctions introduced by way of EU Council Regulations "concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine" ("EU Sanctions"). These EU Sanctions are additional to the existing sanctions in place since 31 July 2014 which were imposed by the EU in response to Russia's actions against Ukraine at that time. These sanctions have been extended on a six monthly basis since that date (for more details in respect of same, please see the Russian entry in the EU Sanctions Map.)
In this Insight we summarise the details of the recent EU Sanctions as they impact Regulated Financial Service Providers ("RFSPs"), outline the international commitment to impose further restrictive measures and reiterate RFSP's obligations regarding compliance with the EU Sanctions.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
