The European Commission has updated its Russia sanctions FAQs on asset freezes and the Central Bank of Russia to cover reporting obligations introduced by the 10th package of Russia sanctions (previous post). It has also updated its consolidated FAQs.
Asset freeze and prohibition to provide funds or economic resources
The Commission has added a section on the reporting obligations introduced by Council Regulation (EU) 2023/426, including FAQs on:
- reporting on information held on changes to assets which took place over the 2 weeks prior to a designation;
- specifics of the information to be provided on frozen assets;
- where / to whom to report on frozen assets; and
- specific cases of central securities depositories, specific frozen assets reporting and common reporting template (available here).
In FAQ 35, the Commission says that, applying from 26 April 2023, article 8 of Council Regulation (EU) No 269/2014 requires operators to report to their national competent authorities on “information held on funds and economic resources within Union territory belonging to, owned, held or controlled by natural or legal persons, entities or bodies listed in Annex I and which have been subject to any move, transfer, alteration, use of, access to, or dealing referred to in Article 1(e) or 1(f) in the two weeks preceding the listing of those natural or legal persons, entities or bodies in Annex I”.
This reporting requirement applies to designations of natural and legal persons, entities and bodies in Annex I to Regulation 269/2014 and therefore to all existing designations.
Central Bank of Russia
The Commission has added a section concerning the obligations to report immobilised assets introduced by Council Regulation (EU) 2023/427, including FAQs on:
- a template for reporting immobilised assets under article 5a(4) of Regulation (EU) No 833/2014 (available here) and reporting timelines; and
- where / to whom to report on immobilised assets.
