on 7 march 2025, the british virgin islands financial services commission (bvi fsc) issued an update through industry circular 12 of 2025 regarding the implementation of beneficial ownership (bo) filing requirements. this blog post outlines the key changes under the bvi business companies and limited partnerships (beneficial ownership) regulations, 2024 and provides guidance on the phased implementation. from 2 january 2025, all bvi business companies and limited partnerships must file their beneficial ownership information through the virrgin system. this regulatory development aligns with international transparency standards and is a significant move toward strengthening corporate compliance within the jurisdiction. key elements of the implementation plan the bo filing regime is being rolled out in phases to ease the transition process for stakeholders. below are the essential components and timelines to keep in mind. key dates: 2 january 2025– filing requirements officially commenced 31 march 2025– schema for batch or bulk filings to be released, facilitating filings for entities handling higher volumes 17 april 2025– batch/bulk filing functionality to become operational the incremental approach provides companies and their agents ample time to adapt to the new system. functionality and filing practicalities to address industry concerns, several aspects of the new system have been clarified: batch/bulk filing feature:highly anticipated by agents managing large-scale filings, this feature will streamline multi-entity data submissions interdependency of registers:information for registers of directors, members, and beneficial owners can be filed independently and in no specific order supporting documentation requirements: documentation is only required if data anomalies, such as missing names or dates of birth, occur common queries addressed in the circular the bvi fsc has provided additional details to clarify some of the recurring concerns raised by stakeholders: exemptions:entities that are subsidiaries of publicly listed companies are exempt from certain bo filing requirements. however, at this time, the filing function in virrgin is not yet available. please refer to the schedule of timelines/dates for the release of all functions accessible through the schedule included in the circular. technical issues: errors in virrgin (ie, 505 error page and 500 error page) could be related to the internet browser being used by the user. chrome and firefox are recommended browsers for optimal performance. the bvi fsc recommends clearing your cache, try using a different browser, and submit your request again. if the problem continues, the bvi fsc requests to send an email with the error message to support@bvifsc.vg or bo@bvifsc.vg. penalties for non-compliance:if attempts to file a transaction are made and the function is not available in virrgin, the company will not incur penalties if the registry is notified of the attempt to file a transaction. a list of entities and the reasons for their non-filing should be submitted to the registrar, and a penalty fee will not be charged to these entities. future updates: updated faqs to address additional concerns are expected to be published shortly and periodically thereafter. for assistance, the bo unit may be contacted by emailing queries to bo@bvifsc.vg or through the help desk at support@bvifsc.vg. the fsc emphasises the importance of adhering to deadlines as outlined in the updated timeline. agents and corporations are advised to monitor the fsc site regularly for updates. circular 12 can be found here. find our in-depth guide here, offering comprehensive insights into the latest developments on bvi's bo regulations.

on 7 march 2025, the british virgin islands financial services commission (bvi fsc) published its detailed timeline for the rollout of key functionalities related to beneficial ownership (bo) filings, as well as the management of registers of directors, registers of members, registers of limited partners, and registers of general partners. this phased approach aims to enhance compliance and operational efficiency for stakeholders. highlights of the timeline the implementation plan introduces various functionalities in a structured sequence, allowing entities to manage their statutory obligations effectively. below are the key features and their respective target launch dates: register of directors (rod) amendment to register of directors - single filing: 16 march 2025 batch filing for registration of directors: 3 april 2025 correction of directors - single filing: 4 april 2025 global change for director corrections: 16 april 2025 global change for director notices: 25 april 2025 register of members (rom) notice of change exemption: 3 april 2025 batch filing for member registration: 4 april 2025 single filing for member corrections: 4 april 2025 global change for member corrections: 20 june 2025 cease register of members and file exemption: 11 july 2025 beneficial ownership (bo) notice of change – cease bo and file exemption: 11 april 2025 notice of change exemption for beneficial ownership: 17 april 2025 batch filing for bo registration: 17 april 2025 single filing for bo corrections: 28 april 2025 global change for bo corrections: 4 june 2025 notice of change of bo (global change): 27 june 2025 register of limited and general partners (rolp/rogp) notice of change exemptions (limited & general partners): 3 april 2025 cease exemption and file of limited or general partners: 3 april 2025 batch filing for changes or corrections (global changes): 24 april 2025 notice of change limited or general partners (global changes): 22 may 2025 these functionalities reflect bvi fsc's commitment to fostering compliance with transparency standards and enhancing ease of filing for stakeholders. phased rollouts, including the introduction of batch filings and global change filings, ensure smoother operations for entities managing multiple filings. streamlining compliance processes the timeline also integrates features for exemptions, enabling firms to streamline their compliance processes while adhering to the updated requirements. these incremental updates underscore the importance of proactive adjustments by companies to avoid penalties and capitalise on operational efficiencies. next steps for stakeholders industry practitioners should familiarise themselves with this timeline and adjust their internal processes to accommodate these changes. with key deadlines rapidly approaching, prompt action will help maintain compliance while reducing administrative burdens. the bvi fsc’s bo implementation timeline can be accessed here. find our in-depth guide here, offering comprehensive insights into the latest developments on bvi's bo regulations.

the cayman islands monetary authority (cima) recently issued a warning notice citing significant breaches of the securities investment business act (sib act) and other key regulations. this guide outlines the key breaches, proposed actions, and valuable lessons for financial entities to ensure compliance. cima highlighted several violations, including: failure to file annual declarations - breach of section 5(4e)(a) of the sib act due to non-submission of declarations for 2024 and 2025. non-payment of annual fees and penalties - failure to pay fees and penalties for 2024 and 2025, contravening section 5(4e)(b). lack of proper directorship - breach of section 15(4)(a) for not maintaining a minimum of two individual directors or one eligible corporate director. non-compliance with cima directions - breach of section 34(17)(a) of the monetary authority act for failing to meet regulatory requirements and directions. failure to maintain a registered office - violation of section 50(1) of the companies act (2023 revision). these breaches indicate an alarming lack of compliance, governance, and communication. proposed enforcement action cima has proposed to revoke the registration of the securities - registered person under section 17(2a) of the sib act. justifications for this action include: failure to comply with statutory obligations. poor management and governance practices. non-adherence to lawful cima directives. lessons and best practices for compliance this enforcement action underscores the importance for financial entities to uphold stringent compliance standards. to avoid similar actions, entities should: implement robust governance - ensure directorship meets statutory requirements and actively monitor compliance. timely reporting - file all annual declarations and pay fees punctually to avoid penalties. maintain transparency - communicate promptly with regulators and respond to their inquiries. review internal controls - regularly assess compliance frameworks to identify and address gaps. seek expert guidance - engage legal and compliance professionals for ongoing advisory support. final takeaway non-compliance carries significant risks, from reputational damage to loss of operating rights. cima’s enforcement action serves as a compelling reminder of the critical need for rigorous adherence to regulatory obligations. institutions must treat compliance as an ongoing priority and as a foundation for trust and sustainability in this highly regulated industry. the cima’s warning notices can be found here.

on 21 february 2025, the bvi financial services commission (fsc) released a series of three educational videos designed to develop understanding and bolster compliance regarding proliferation financing (pf). these videos serve as a valuable resource for licensed entities seeking to enhance their risk management strategies. covering essential topics, the videos explain what pf entails, provide illustrative examples of pf typologies, and outline the responsibilities of supervised entities. key areas of focus include the importance of ongoing monitoring, effective sanctions screening and accurate reporting procedures. the fsc urges licensees to not only review the material themselves but also encourage their teams to engage with these resources. familiarity with the guidance provided in these videos can help entities meet their obligations more effectively and adapt to the evolving risks related to money laundering, terrorism financing, and pf. vigilance remains critical. by implementing robust aml/cft/cpf measures, entities can enhance compliance efficiency and build resilience against emerging threats. the videos can be accessed here and the circular 11 can be found here.

on 7 february 2025, the central bank of cyprus (cbc) issued a warning to investors about the risks associated with crypto assets, for the purposes of protecting financial stability and consumer protection. while the application of blockchain technology holds great promise within the financial sector —particularly in payment systems and potential central bank digital currencies (cbdcs) — the cbc noted that crypto-assets remain highly volatile, speculative, and vulnerable to fraud. despite the introduction of eu regulation 2023/1114 on markets in crypto assets (mica regulation) which improved transparency and efficiency within the area of crypto assets, the area still suffers from important risks which include inadequate regulatory safeguards and financial crime exposure. the cbc clarified that crypto assets are unsuitable as reserve assets, and no cyprus bank invests in them. the cbc urges investors to exercise caution when they invest in crypto assets in order to avoid substantial financial losses and fraud. the official announcement of the cbc can be found here.

on 3 february 2025, the bermuda monetary authority (bma) launched a call for proposals to explore embedded supervision within decentralised finance (defi). this initiative aims to integrate regulatory oversight directly into blockchain-based financial ecosystems, ensuring compliance through automation. embedded supervision leverages technology to automate compliance and reporting, enabling real-time regulatory oversight within defi platforms. the bma’s approach is to enhance the effectiveness and efficiency of financial regulation in an increasingly decentralised world. objectives of the pilot project the initiative seeks to: understand defi risks and regulation: collaborate with industry stakeholders to develop adaptive, risk-based regulatory frameworks. assess technical feasibility and operational efficacy: identify key components for embedded supervision and evaluate automated compliance mechanisms. monitoring risk and develop best practices: monitor risk parameters, assess efficiency gains, and establish regulatory guidelines for defi oversight. why it matters defi is a transformative financial services ecosystem built on distributed ledger technology (dlt), aiming to enhance accessibility, transparency, and efficiency through decentralisation. key components include smart contracts, peer-to-peer networks, and protocols, which operate without traditional intermediaries. despite its benefits, defi presents unique regulatory challenges. key concerns include: decentralisation complexity: determining responsibility for compliance in distributed networks. aml/kyc challenges: adapting anti-money laundering and identity verification processes. global operations: navigating cross-border regulatory frameworks. rapid innovation: keeping pace with defi’s evolving technologies and governance models. potential pilot projects the bma encourages creative proposals, including: regulatory decentralised autonomous organisation (dao) implementation: testing a decentralised governance model with bma participation. smart contract compliance: embedding regulatory conditions into defi smart contracts. real-time compliance reporting: automating data collection and compliance checks in real-time. defi lending oversight: supervising lending platforms with embedded risk monitoring. the bma invites defi operators, fintech firms, protocol developers, digital asset businesses, academic institutions, and other industry stakeholders to participate in this initiative. interested participants must submit a proposal by 30 april 2025 via email to fintech@bma.bm. proposals should outline objectives, methodology, technological framework, risk assessment, and regulatory alignment. for full details, bma’s official consultation can be found here.

on 29 january 2025, luxembourg’s tax authority published circular l.i.r. n° 164/1, replacing the guidelines issued in 1998. this development modernises the rules for determining interest rates applicable to shareholder current accounts, introducing critical changes grounded in the arm’s length principle. what was changed? elimination of the fixed 5 per cent ratethe long-standing fixed interest rate of 5 per cent for shareholder current accounts is no longer valid. instead, interest rates must align with market conditions and reflect terms that independent parties would agree to, adhering to the arm’s length principle. simplified approach for individual shareholdersto ease compliance, companies may reference annual consumer credit rates published by the central bank of luxembourg. the average of monthly rates during the relevant financial period can serve as a benchmark, provided supporting documentation is maintained. clarification for associated enterprisesfor transactions between associated enterprises (eg, intercompany loans), the circular reiterates that interest rates must be determined on a case-by-case basis, factoring in elements such as currency, credit risks, refinancing rates, and loan maturity. implications for businesses and shareholders this shift calls for a proactive approach to compliance. luxembourg companies should review and align their position with the updated guidelines, ensuring proper documentation to substantiate arm’s length terms. individual shareholders should also reassess their tax positions to mitigate any risks. for guidance on implementing these updates, consult our tax experts. the circular l.i.r. n° 164/1 (in french) can be found here.

the european central bank (ecb) has issued decision (eu) 2025/222 of 27 january 2025 which grants non-bank payment service providers (psps) access to eurosystem central bank operated payment systems and central bank accounts (the decision). this move aims to enhance competition and innovation in the european payments landscape by creating equal opportunities between traditional banks and non-bank psps. the decision: outlines when a eurosystem central bank should provide access to its central bank operated payment systems for a non-bank psp; prohibits eurosystem central banks from offering or providing safeguarding accounts to non-bank psps or to crypto-asset services providers; lays out the maximum holding amounts by a non-bank psp; and sets out penalties in relation to non-compliance with the maximum holding amount limit or the requirements for access to central bank operated payment systems. the decision aims to reflect the ecb's stated commitment to fostering a diverse and competitive financial environment, ultimately benefiting consumers and businesses with more choices and improved payment services. the decision (eu) 2025/222 of the european central bank will apply from 9 april 2025 and can be accessed here.

on 21 february 2025, the bvi financial services commission (fsc) released its revised handbook on international co-operation and information exchange. this updated guide reflects the bvi’s commitment to international collaboration in tackling critical global issues, including money laundering, terrorism financing, and the proliferation of weapons of mass destruction. why international cooperation matters international cooperation plays a vital role in fighting organised crime, which often transcends national borders and relies on exploiting legitimate institutions to mask illicit activities. criminal networks use these means to fund further unlawful undertakings, making cross-border collaboration essential in the global fight against such threats. the bvi recognises that efficient crime prevention requires countries to work together in robust and multifaceted ways, ensuring no jurisdiction becomes a safe haven for those engaged in criminal activities. mechanisms such as mutual legal assistance and extradition exemplify how countries can collectively pursue justice. by facilitating the extradition of fugitives or sharing critical legal intelligence, jurisdictions can protect their communities and ensure the stability of their financial systems. over the past three decades, the bvi has prioritised these efforts by continuously refining its cooperation regimes to align with international standards and developments. the global nature of organised crime extends its reach into regulated markets, with examples such as tax evasion, securities manipulation, insider trading, and corporate abuse. these activities threaten the integrity of financial systems and undermine investor confidence. to counter this, the bvi's cooperation frameworks not only protect domestic interests but also contribute to safeguarding global economic stability. a testament to the bvi's commitment the handbook on international co-operation and information exchange serves as a vital resource for regulators, judicial officials and law enforcement. with structures designed to uphold the integrity of the territory's legal and financial frameworks, it showcases the bvi’s proactive and collaborative stance in combating crime across borders. by implementing such measures, the bvi bolsters its dedication to maintaining a secure and stable financial environment. the revised handbook offers a comprehensive guide to its methods of international cooperation and information-sharing protocols. the official press release can be found here and the handbook here.

further to our blog post on eu russia sanctions, please find below an updated table of sanctions. name of instrument date published amends or implements? comes into force summary of key provisions council regulation (eu) 2022/259 23 february 2022 regulation (eu) no 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (regulation 269) on publication date but with reference to 24 august 2022 new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. council implementing regulation (eu) 2022/260 23 february 2022 regulation 269 on publication date addition of 22 russian government figures/individuals and four entities added to the asset freeze list under regulation 269, related to the recognition by russia of donetsk and luhansk breakaway republics. council implementing regulation (eu) 2022/261 23 february 2022 regulation 269 on publication date addition of 336 members of the russian state duma to the asset freeze list under regulation 269, related to the vote on recognition of the breakaway republics. council decision (cfsp) 2022/265 23 february 2022 decision 2014/145/cfsp concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (decision 145) on publication date new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. addition of 22 russian government figures/individuals and four entities added to the asset freeze list under decision 145, related to the recognition by russia of donetsk and luhansk breakaway republics. council decision (cfsp) 2022/267 23 february 2022 decision 145 on publication date addition of 336 members of the russian state duma to the asset freeze list under decision 145, related to the vote on recognition of the breakaway republics. council regulation (eu) 2022/262 23 february 2022 regulation (eu) no 833/2014 concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (regulation 833) on publication date but with reference to 9 march 2022 new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council decision (cfsp) 2022/264 23 february 2022 decision 2014/512/cfsp concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (decision 512) on publication date new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council regulation (eu) 2022/263 concerning restrictive measures in response to the recognition of the non-government controlled areas of the donetsk and luhansk oblasts of ukraine and the ordering of russian armed forces into those areas 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. luhansk/donetsk embargo. council decision (cfsp) 2022/266 concerning restrictive measures in response to the recognition of the non-government controlled areas of the donetsk and luhansk oblasts of ukraine and the ordering of russian armed forces into those areas 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. council implementing regulation (eu) 2022/300 (regulation 300) 24 february 2022 regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus (regulation 765) on day following publication date implementing article 8a of regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus. some changes to reasoning of designation. not directly relevant to russia-ukraine conflict but contemporaneous with it. council decision (cfsp) 2022/307 24 february 2022 decision 2012/642/cfsp concerning restrictive measures in view of the situation in belarus (decision 642) on day following publication date materially equivalent to measures referred to in regulation 300. not directly relevant to russia-ukraine conflict but contemporaneous with it. decision (eu) 2022/313 of the european parliament and of the council of 24 february 2022 providing macro-financial assistance to ukraine 24 february 2022 n/a. new measure on day following publication date provision of macro-financial assistance to support ukraine’s commitment to values shared with the eu, including democracy, the rule of law, good governance, respect for human rights, sustainable development and poverty reduction, as well as its commitment to the principles of open, rule-based and fair trade. not directly relevant to russia-ukraine conflict but contemporaneous with it. council regulation (eu) 2022/328 (regulation 328) 25 february 2022 regulation 833 on day following publication date, however many measure come into force from 12 april 2022 imposition of numerous restrictive measures in various sectors of the russian economy, specifically defence, energy, aviation and finance. restrictions and prohibitions on: exports of dual-use goods and technology and on the provision of related services, as well as restrictions on exports of certain goods and technology which might contribute to russia’s technological enhancement of its defence and security sector (articles 2, 2a, 2b, 2c) the provision of public financing or financial assistance for trade with, or investment in, russia, subject to certain exceptions (article 2e) the sale, supply, transfer or export to russia of specific goods and technologies for use in oil refining, together with restrictions on the provision of related services (article 3b) export ban covering goods and technology suited for use in aviation and the space industry and prohibits the provision of insurance and reinsurance and maintenance services in relation to those goods and technology (article 3c) expanding the existing financial restrictions, in particular those on access by certain russian entities to the capital markets – including elimination of maturity periods for debt issued after 12 april 2022 (article 5) addition of new annex xii (now includes alfa bank and otkritie bank) the listing and provision of services in relation to shares of russian state-owned entities on union trading venues (article 5(5)) the acceptance of deposits exceeding certain values from russian nationals or residents (article 5b), the holding of accounts of russian clients by eu based central securities depositories (article 5e) as well as the sale of euro-denominated securities to russian clients (article 5e) bank account reporting requirements where eu bank accounts hold in excess of €100,000 (article 5g) council decision (cfsp) 2022/327 25 february 2022 decision 512 on day following publication date, however many measure come into force from 12 april 2022 equivalent to those listed under regulation 328. council regulation (eu) 2022/330 25 february 2022 regulation 269 on publication date recasting and expanding designation criteria for asset freeze under regulation 269. council decision (cfsp) 2022/329 25 february 2022 decision 145 on publication date recasting and expanding designation criteria to include persons and entities supporting and benefitting from the government of the russian federation as well as persons and entities providing a substantial source of revenue to it, and natural or legal persons associated with listed persons or entities. council implementing regulation (eu) 2022/332 (regulation 332) 25 february 2022 regulation 269 on publication date addition of: members of the russian national security council who supported russia's immediate recognition of the two self-proclaimed republics donetsk and luhansk persons who facilitated the russian military aggression from belarus, as well as those members of the state duma not yet included in that list who ratified the government decisions of the 'treaty of friendship, cooperation and mutual assistance between the russian federation and the donetsk people's republic and between the russian federation and the luhansk people's republic comprises 98 new individuals including president vladimir putin and minister of foreign affairs sergei lavrov. council decision (cfsp) 2022/331 25 february 2022 decision 145 on publication date measures equivalent to those in regulation 332. council decision (eu) 2022/333 on the partial suspension of the application of the agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia 25 february 2022 2007 agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia (2007 visa agreement) on publication date suspends application of 2007 visa agreement, including as relevant to business people and representatives of business organisations. council regulation (eu) 2022/334 28 february 2022 regulation 833 on publication date prohibition for any aircraft operated by russian air carriers, including as a marketing carrier in codesharing or blocked-space arrangements, or for any russian registered aircraft, or for any non-russian-registered aircraft which is owned or chartered, or otherwise controlled by any russian natural or legal person, entity or body, to land in, take off from or overfly the territory of the eu (article 3d). prohibition on transactions related to the management of reserves as well as of 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, are prohibited (article 5a(4)). council decision (cfsp) 2022/335 28 february 2022 decision 512 on publication date prohibition of any transactions with the central bank of russia. russia central bank asset freeze (article 1a). denial of permission to land in, take off from, or overfly, their territories to any aircraft operated by russian air carriers, including as a marketing carrier, to any russian-registered aircraft, and to non-russian-registered aircraft which are owned or chartered, or otherwise controlled by a russian legal or natural person (article 4e). council decision (cfsp) 2022/338 on an assistance measure under the european peace facility for the supply to the ukrainian armed forces of military equipment, and platforms, designed to deliver lethal force 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 establishment of an assistance measure benefitting ukraine financed under the european peace facility (epf). the objective of the assistance measure is to contribute to strengthening the capabilities and resilience of the ukrainian armed forces to defend the territorial integrity and sovereignty of ukraine and protect the civilian population against the ongoing military aggression. provides for a centralised budget framework and reporting coordination between ministries of defence of the eu member states. council decision (cfsp) 2022/339 on an assistance measure under the european peace facility to support the ukrainian armed forces 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 provision of assistance measures calling for contributions up to €50,000,000. the funds called by the administrator for assistance measures to be used to pay expenditure within the limits approved by the committee established by decision (cfsp) 2021/509 in the 2022 amending budget corresponding to the assistance measure. council implementing regulation (eu) 2022/336 28 february 2022 regulation 269 on publication date addition of: numerous ultra-high net worth russian businessmen (oligarchs) including igor sechin, chief executive of rosneft oil co. alexey mordashov, the majority owner of steel giant severstal pao alisher usmanov mikhail fridman and petr aven, founders of alfa bank the measures also target key kremlin officials including dimitry peskov, vladimir putin’s press secretary; several journalists the eu accuses of anti-ukrainian propaganda; and military officers council decision (cfsp) 2022/337 28 february 2022 regulation 269 on publication date measures equivalent to those in regulation 336. council regulation (eu) 2022/345 1 march 2022 regulation 833 on publication date imposing further restrictive measures with regard to the provision of specialised financial messaging services to certain russian credit institutions and their russian subsidiaries, which are relevant for the russian financial system and which are already the subject of restrictive measures imposed by the union or by partner countries and, subject to certain exceptions, with regard to engagement with the russian direct investment fund. it also prohibits, subject to certain exceptions, the supply of euro banknotes to russia. these measures fall within the scope of the treaty and, therefore, in particular with a view to ensuring their uniform application in all member states, regulatory action at the level of the union is necessary. council decision (cfsp) 2022/346 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 345. council regulation (eu) 2022/350 1 march 2022 regulation 833 on publication date prohibition on the broadcasting and the facilitation of broadcasting by the following media outlets, including through transmission/distribution by any means such as cable, satellite, ip-tv, internet service providers, internet video-sharing platforms or apps: sputnik rt – russia today english rt – russia today uk rt – russia today germany rt – russia today france rt – russia today spanish these measures also suspend any broadcasting licence, authorisation or arrangement with the above entities. council decision (cfsp) 2022/351 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 350. council regulation (eu) 2022/353 2 march 2022 regulation 269 on publication date addition of 22 belarusian individuals to the asset freeze list under regulation 269. council decision (cfsp) 2022/354 2 march 2022 decision 145 on publication date equivalent to those listed under regulation 353 above. council regulation (eu) 2022/355 2 march 2022 regulation 765 on publication date renames the regulation 765 to refer expressly to the fact that these measures relate also to the involvement of belarus in the russian aggression against ukraine. introduces extensive new prohibitions with respect to dealing with belarus, some of these equivalent to the prohibitions introduced on russia under regulation 328 (eg in relation to dual-use goods and technology, goods and technology which might contribute to belarus’s military and technological enhancement), as well as a number of prohibitions with respect to wood, cement, iron, steel and rubber products and specific machinery as listed in the regulation. council decision (cfsp) 2022/356 2 march 2022 decision 642 on publication date equivalent to those listed under regulation 356 above. council implementing regulation (eu) 2022/375 4 march 2022 (but dated 3 march) regulation (eu) no 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date update following a review by the council, on the rights of defence and effective judicial protection on individuals charged with the misappropriation of ukrainian state funds, including former ukrainian president yanukovych (now thought to be in hiding in russia). council decision (cfsp) 2022/376 4 march 2022 (but dated 3 march) decision 2014/119/cfsp concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date equivalent to those listed under implementing regulation 375 above. council implementing regulation (eu) 2022/396 9 march 2022 regulation 269 on publication date adds a further 160 persons to the asset freeze list under regulation 269, including persons owning or holding senior management positions or otherwise connected to prominent russian businesses considered to support the russian government, as well as a number of persons of the federation council who ratified the government decisions to recognise the declaration of independence of the donetsk and luhansk regions. council decision (cfsp) 2022/397 9 march 2022 decision 145 on publication date equivalent to those listed under implementing regulation 397 above. council regulation (eu) 2022/394 9 march 2022 regulation 833 on publication date extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets”. this regulation also introduces a new prohibitions in relation to maritime navigation goods and technology to any natural or legal person, entity or body in russia, for use in russia, or for the placing on board of a russian-flagged vessel. council decision (cfsp) 2022/395 9 march 2022 decision 512 on publication date equivalent to those listed under regulation 394 above. council regulation (eu) 2022/398 9 march 2022 regulation 765 on publication date expands the existing financial restrictions under the belarus sanctions to include prohibitions similar to those already included under regulation 833 on russia. in particular, it prohibits the listing and provision of services in relation to shares of belarusian state-owned entities on eu trading venues. in addition, it introduces new measures which significantly limit the financial inflows from belarus to the union by prohibiting the acceptance of deposits exceeding certain values from belarusian nationals or residents, the holding of accounts of belarusian clients by the eu central securities depositories as well as the selling of euro-denominated securities to belarusian clients. it also prohibits transactions with the central bank of belarus related to the management of reserves or assets, the provision of public financing for trade with and investment in belarus, with limited exceptions, and the provision of euro denominated banknotes to belarus or for use in belarus it also imposes further restrictive measures with regard to the provision of specialised financial messaging services to certain belarusian credit institutions and their belarusian subsidiaries, which are relevant for the belarusian financial system and which are already the subject of restrictive measures imposed by the union it also extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets” this also adds obligations on the network manager for air traffic management network functions of the single european sky regarding overflight prohibitions and amend the provisions on non-circumvention council decision (cfsp) 2022/399 9 march 2022 decision 642 on publication date equivalent to those listed under regulation 398 above. council regulation (eu) 2022/408 11 march 2022 regulation 269 on publication date amends the information concerning 37 individuals and six entities already included under regulation 269. council decision (cfsp) 2022/411 11 march 2022 decision 145 on publication date equivalent to those listed under regulation 408 above. council regulation (eu) 2022/427 15 march 2022 regulation 269 on publication date adds a further 15 individuals and 9 entities to the asset freeze list under regulation 269, including among others prominent figures such as roman abramovich. council regulation (eu) 2022/428 15 march 2022 regulation 833 on publication date introduces further sectoral restrictive measures, as follows: prohibits all transactions with certain state-owned companies prohibit the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities, to any russian person or entity tightens export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, and expands the list of persons connected to russia’s defence and industrial base, which are subject to those restrictions prohibits new investments in the russian energy sector, and introduces a comprehensive export restriction on equipment, technology and services for the energy industry in russia, with the exception of nuclear industry and the downstream sector of energy transport introduces further trade restrictions concerning iron and steel, as well as on luxury goods council decision (cfsp) 2022/429 15 march 2022 decision 145 on publication date equivalent to those listed under regulation 427 above. council decision (cfsp) 2022/430 15 march 2022 decision 512 on publication date equivalent to those listed under regulation 428 above. council regulation (eu) 2022/580 8 april 2022 regulation 269 on publication date expands the provisions of article 6b of regulation 269 to provide for further grounds for persons to apply for a licence to be exempted from the asset freeze restrictions. in particular, the amendments introduce: as relevant to the latest russian banks addedto the asset freeze list (i.e. vtb, otkritie, novikombank and sovcombank), the possibility to apply for a licence for those entities to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to those entities, for the purposes of termination by 9 october 2022 of operations, contracts, or other agreements, including correspondent banking relations, concluded with those entities before 8 april 2022 as relevant generally to persons included on the asset freeze list, the possibility to apply for a licence for such asset frozen persons to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to such persons, provided that the relevant competent authority is able to determine that: the funds or economic resources are necessary for the sale and transfer by 9 october 2022 of proprietary rights in a legal person, entity or body established in the union where those proprietary rights are directly or indirectly owned by a natural or legal person, entity or body listed in annex i the proceeds of such sale and transfer remain frozen council implementing regulation (eu) 2022/581 8 april 2022 regulation 269 on publication date adds a further 216 individuals and 18 entities to the asset freeze list, notably including four russian banks (vtb, otkritie, novikombank and sovcombank) as well as further high profile russian government officials and businessmen. council decision (cfsp) 2022/582 8 april 2022 decision 145 on publication date equivalent to those listed under regulation 581 above. council regulation (eu) 2022/576 8 april 2022 regulation 833 on publication date introduces further sectoral prohibitions, as follows: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector introduces additional import restrictions on certain goods from russia, in particular on coal and other solid fossil fuels introduces further export restrictions to russia, in particular on jet fuel and other goods prohibits the award and continued execution of public contracts and concessions with russian nationals and entities or bodies established in russia imposes a prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to russian publicly owned or controlled entities extends the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of the member states extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for the purchase, import or transport of fossil fuels and certain minerals into switzerland, the eea and the western balkans extends the exemptions from the prohibition on transaction with certain russian state-owned enterprises and their subsidiaries to countries in the european economic area and switzerland as well as to the western balkans introduces a prohibition for road transport undertakings established in russia to transport goods by road in the eu prohibits access to ports to vessels registered under the flag of russia notably, introduces a prohibition on acting as a trustee or in similar capacities for russian persons and entities, as well as a prohibition on providing certain services to trusts council regulation (eu) 2022/577 8 april 2022 regulation 765 on publication date introduces further sectoral prohibitions, as follows: imposes further restrictive measures prohibiting the sale to belarus of transferable securities denominated in any official currency of a member state, and prohibiting the sale, supply, transfer or export to belarus of banknotes denominated in any official currency of a member state imposes further restrictive measures prohibiting road transport undertakings established in belarus from transporting goods by road within the territory of the european union council decision (cfsp) 2022/578 8 april 2022 decision 512 on publication date equivalent to those listed under regulation 576 above. council decision (cfsp) 2022/579 8 april 2022 decision 642 on publication date equivalent to those listed under regulation 577 above. council regulation (eu) 2022/625 13 april 2022 regulation 269 on publication date adds exceptions to the freezing of the assets of, and the restrictions on making funds and economic resources available to, designated persons, entities and bodies for certain clearly defined categories of bodies, persons, entities, organisations and agencies for exclusively humanitarian purposes in ukraine. council decision (cfsp) 2022/627 13 april 2022 decision 145 on publication date equivalent to those listed under regulation 625 above. council regulation (eu) 2022/626 13 april 2022 regulation 263 on publication date adds exceptions that allow clearly defined categories of bodies, persons, entities, organisations and agencies to provide goods and technology for use in certain sectors, as well as certain restricted services and assistance related to such goods and technology, to persons, entities and bodies in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine or for use in those areas, where necessary for humanitarian purposes. similarly, the exceptions allow for the provision of specific restricted services and assistance directly relating to certain infrastructure in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine, where necessary for humanitarian purposes. luhansk/donetsk embargo. council decision (cfsp) 2022/628 13 april 2022 decision 266 on publication date equivalent to those listed under regulation 626 above. council regulation (eu) 2022/658 21 april 2022 regulation 269 on publication date adds a further two individuals to the asset freeze list. council decision (cfsp) 2022/660 21 april 2022 decision 145 on publication date equivalent to those listed under regulation 658 above. council regulation (eu) 2022/876 3 june 2022 regulation 765 on publication date adds a further two individuals and eight entities should be included in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 (belarussian asset freeze list). council regulation (eu) 2022/877 3 june 2022 regulation 765 on publication date expands the list of entities subject to restrictions with regard to authorisations for the sale, supply, transfer or export of dual-use goods and technology, and goods and technology which might contribute to belarus’s military and technological enhancement, or to the development of its defence and security sector. this amendment also expands the list of belarusian credit institutions and their belarusian subsidiaries subject to a swift ban. it also includes provisions clarifying and strengthening the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements council regulation (eu) 2022/878 3 june 2022 regulation 269 on publication date adds a further 65 individuals and 18 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 269 (russian asset freeze list). council regulation (eu) 2022/879 3 june 2022 regulation 833 on publication date this is the key legal instrument introducing the new sectoral prohibitions under the sixth package. the new prohibitions consist of: oil imports: introduction of an embargo on the import of crude oil and refined oil products from russia, with a programme to gradually phase out russian oil imports. these provisions include temporary exemptions for certain cases where member states are heavily dependent on russian oil oil transport services: after a wind down period of 6 months, eu operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to third countries financial services: an additional three russian banks, including russia's largest bank sberbank, have been removed from swift business services: the deadline for winding down certain prohibited trust services has been extended to 5 july 2022 and those provisions have been further refined. this latest package also introduces a prohibition on the provision to the russian government, as well as to legal persons, entities or bodies established in russia of certain business-relevant services such as accounting, auditing, statutory audit, bookkeeping and tax consulting services, business and management consulting, and public relations services broadcasting suspension: the broadcasting activities of rossiya rtr/rtr planeta, rossiya 24/russia 24, and tv centre international – have been suspended. the advertising of products or services on sanctioned outlets has also been prohibited export restrictions: the list of advanced technology items banned from export to russia has been expanded to include additional chemicals that could be used in the process of manufacture of chemical weapons penalties: this amendment also clarifies and strengthen the provisions on national penalties for the breach of the sanctions under regulation 833 council regulation (eu) 2022/880 3 june 2022 regulation 269 on publication date introduces further derogation options from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities. this amendment also clarifies and strengthens the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements. council decision (cfsp) 2022/881 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 876 above. council decision (cfsp) 2022/882 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 877 above. council decision (cfsp) 2022/883 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 878 above. council decision (cfsp) 2022/884 3 june 2022 decision 512 on publication date equivalent to those listed under regulation 879 above. council decision (cfsp) 2022/885 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 880 above. regulation (eu) 2022/1280 of the european parliament and of the council 18 july 2022 n/a. new measure on publication date laying down specific and temporary measures, in view of russia’s invasion of ukraine, concerning driver documents issued by ukraine in accordance with its legislation. council regulation (eu) 2022/1269 (regulation 1269) 21 july 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector imposes a prohibition on the direct or indirect import, purchase or transfer of gold, which constitutes russia’s most significant export after energy extends the port access ban to locks allows, the sharing of technical assistance with russia in relation to aviation goods and technology to safeguard the technical industrial standard setting process of the international civil aviation organization (icao) introduces an exemption from the prohibition to enter into any transactions with russian public entities necessary to ensure access to judicial, administrative or arbitral proceedings harmonises the notification requirements for national competent authorities granting authorisations pursuant to derogations provided expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for agricultural products and the supply of oil and petroleum products to third countries this regulation also includes clarifications that the measures in regulation 833 do not prevent third countries and their nationals from trading with russia or trading in russian goods. council implementing regulation (eu) 2022/1270 21 july 2022 regulation 269 on publication date adds a further 48 persons and 9 entities to the asset freeze list under regulation 269, most notably sberbank which to date had not been listed. council decision (cfsp) 2022/1271 21 july 2022 decision 512 on publication date equivalent to those listed under regulation 1269 (amending regulation 833) above. council regulation (eu) 2022/1273 (regulation 1273) 21 july 2022 regulation 269 on publication date introduces a number of derogations to the asset freeze provisions of regulation 269: further derogation from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities in order to urgently prevent or mitigate an event likely to have a serious and significant impact on human health and safety or the environment derogation from the asset freeze and the prohibition to make funds and economic resources available to the key designated russian banks (being bank rossiya, promsvyazbnak, vnesheconombank (veb), otkiritie, novikombank, sovcombank, vtb bank and sberbank derogation from the asset freeze and the prohibition to make funds and economic resources available for the orderly wind-down of operations, including correspondent banking relations with respect to sberbank it additionally introduces requirements on designated persons and entities to report assets held within a member state and further strengthens the reporting obligations on eu operators to prevent breaches and circumvention of the asset freeze. council decision (cfsp) 2022/1272 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1273 (amending regulation 269) above. council implementing regulation (eu) 2022/1274 (regulation 1274) 21 july 2022 regulation 269 on publication date imposes an asset freeze on six individuals and one entity related to syrian regime involved in the recruitment of syrian mercenaries to fight in ukraine alongside russian troops. council decision (cfsp) 2022/1276 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1274 above. regulation (eu) 2022/1278 of the european parliament and of the council 22 july 2022 regulation 508 on publication date introduces measures to mitigate the impact of russia’s war of aggression against ukraine on the fishery and aquaculture sector. council implementing regulation (eu) 2022/1354 (regulation 1354) 4 august 2022 regulation 269 on publication date added two further individuals to the asset freeze list: oleksandr viktorovych yanukovych viktor fedorovych yanukovych council decision (cfsp) 2022/1355 4 august 2022 decision 145 on publication date equivalent to those listed under regulation 1354 above. council decision (cfsp) 2022/1355 (regulation 1446) 1 september 2022 regulation 269 on publication date added three further individuals to the asset freeze list. council decision (cfsp) 2022/1355 1 september 2022 decision 145 on publication date equivalent to those listed under regulation 1446 above. council regulation (eu) 2022/1903 (regulation 1903) 6 october 2022 regulation 263 on publication date extends the geographical scope of the restrictions to cover all the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia. council decision (cfsp) 2022/1908 6 october 2022 decision 266 on publication date equivalent to those listed under regulation 1903 above. council regulation (eu) 2022/1904 (regulation 1904) 6 october 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends 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 prohibits the sale, supply, transfer or export of firearms, their parts and essential components and ammunition extends the import ban on steel products and imposes import and export prohibitions on further products originating from russia (such as woodpulp, paper and certain elements used in the jewellery industry such as stones and precious metals, among others) as well imposing restrictions on the sale, supply, transfer or export of additional goods used in the aviation sector introduces an exemption from the prohibition to provide technical assistance, brokering services, financing or financial assistance regarding maritime transport to third countries of crude oil or petroleum products which originate or are exported from russia, purchased at or below a pre-established price cap implements various provisions in connection with the introduction of a price cap as agreed by the price cap coalition expands the prohibitions related to the provision of services for the maritime transport of crude oil and certain petroleum products to third countries, to further prohibit the maritime transport of such goods to third countries, subject to implementation of the price cap expands the prohibition to engage in any transaction with certain russian state-owned or controlled legal persons, entities or bodies by including a ban on union nationals to hold any posts on the governing bodies of those legal persons, entities or bodies adds to the list of russian state-owned or controlled entities that are subject to the transaction ban of the russian maritime register of shipping; extends the port access and lock ban in the territory of the union to vessels certified by the russian maritime register of shipping bans the provision on crypto-asset wallet account or custody services, regardless of the total value of crypto assets extends the prohibition on the provision of certain services to the russian federation by including architectural, engineering, it consultancy and legal advisory services council decision (cfsp) 2022/1909 6 october 2022 decision 512 on publication date equivalent to those listed under regulation 1904 above. council regulation (eu) 2022/1905 (regulation 1905) 6 october 2022 regulation 269 on publication date introduced a further criterion for the listing of natural or legal persons, entities or bodies subject to asset freeze and the prohibition to make funds and economic resources available to designated persons and entities, allowing persons identified to facilitate infringements of the prohibition against circumvention of the provisions of regulation 269, to also be listed. it additionally introduces further derogations from the asset freeze and the prohibition to make funds or economic resources available and introduces additional provisions regarding member states’ obligations regarding the granting of derogations. council implementing regulation (eu) 2022/1906 (regulation 1906) 6 october 2022 regulation 269 on publication date adds a further 30 persons and 7 entities to the asset freeze list under regulation 269. council decision (cfsp) 2022/1907 6 october 2022 decision 145 on publication date equivalent to those listed under regulation 1905 and regulation 1906 above. council implementing regulation (eu) 2022/1985 (regulation 1985) 20 october 2022 regulation 269 on publication date adds 3 iranian persons and 1 entity to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/1986 20 october 2022 decision 145 on publication date equivalent to those listed under regulation 1985 above. council implementing regulation (eu) 2022/2229 (regulation 2229) 14 november 2022 regulation 269 on publication date adds 2 iranian individuals and 2 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2233 14 november 2022 decision 145 on publication date equivalent to those listed under regulation 2229 above. council regulation (eu) 2022/2367 (regulation 2367) 3 december 2022 regulation 833 on publication date establishes the price cap, which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. clarifies the existing prohibition on the trading and brokering of russian crude oil and petroleum products and extends the price cap exemption when such goods are traded at or below the price cap. extends the transition period applicable to the transport of crude oil and certain petroleum products after every subsequent change in the price cap for a period of 90 days to the provision, directly or indirectly, of technical assistance, brokering services or financing or financial assistance, related to the transport, subject to the same conditions, to ensure consistent implementation of the price cap by all operators. introduces a transitional period of 45 days for vessels carrying crude oil originating in russia, which was purchased and loaded onto the vessel prior to 5 december 2022 and unloaded at the final port of destination prior to 19 january 2023. clarifies that the prohibition to provide services related to the transport of russian crude oil or petroleum products by a third country flagged vessel applies in relation to vessels which in the past transported such goods purchased above the price cap, provided the operator responsible for that transport knew or had reasonable cause to suspect that this was the case. introduces an exemption from the prohibitions of providing maritime transport and technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries where necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters. introduces a regular review of the price cap mechanism as of mid-january 2023 and every two months thereafter. such review needs to take into account the objectives of the price cap, including its ability to reduce russia’s oil revenues, as well as the principle that the price cap should be at least 5% below the average market price for russian oil and petroleum products. commission implementing regulation (eu) 2022/2368 (regulation 2368) 3 december 2022 regulation 833 on publication date introduces the price cap (usd 60 / barrel) which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. council decision (cfsp) 2022/2369 3 december 2022 decision 512 on publication date equivalent to those listed under regulations 2367 and 2368 above. council implementing regulation (eu) 2022/ 2430 (regulation 2430) 12 december 2022 regulation 269 on publication date adds 4 iranian individuals and 4 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2432 12 december 2022 decision 145 on publication date equivalent to those listed under regulation 2430 above. council regulation (eu) 2022/2474 (regulation 2474) 16 december 2022 regulation 833 on publication date extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding drone engines, further chemical and biological equipment, riot control agents and electronic components. expands the list of entities connected to russia’s military and industrial complex, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed by adding 168 new entities. extends the suspension of the broadcasting licences in the union of certain russian media outlets. furthers the already existing prohibition targeting new investments in the russian energy sector by additionally prohibiting new investments in the russian mining sector, with the exception of mining and quarrying activities involving certain critical raw materials. expands the export ban covering goods and technology suited for use in aviation and the space industry to include aircraft engines and their parts. introduces a derogation allowing the provision of technical assistance related to the use of goods and technology suited for use in aviation or the space industry, when this is necessary to avoid collision between satellites, or their unintended re-entry into the atmosphere. introduces a possibility for the national competent authorities to grant derogations to allow for certain aviation goods, which are also widely used in the medical field, to be exported for medical, pharmaceutical and humanitarian purposes. extends the list of goods which could contribute to the enhancement of russian industrial capacities by including such items as generators, toy drones, laptops, hard drives, it components, night-vision and radio-navigation equipment, cameras and lenses. extends for an additional six months the exemption applicable to the imports of methanol originating in or exported from russia. clarifies that, as is the case for the member states importing russian crude oil by pipeline, bulgaria cannot sell petroleum products obtained from russian crude oil imported on the basis of that derogation to buyers located in other member states or in third countries. bunkering or refuelling of a vehicle or aircraft in the member states which benefit from those derogations does not fall under that prohibition. allows hungary, slovakia and bulgaria to export to ukraine certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question, including, when necessary, by transiting through other member states. allows bulgaria to export to third countries certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question. introduces a reporting obligation for the operators engaged in transactions concerning natural gas condensate from lng productions plants. adds the russian regional development bank to the list of russian state-owned or controlled entities that are subject to the transaction ban. bans union nationals from holding any posts on the governing bodies of all russian state-owned or controlled legal persons, entities or bodies that are established in russia, subject to certain derogations. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. introduces a temporary derogation from the import and export prohibitions, by enabling the sale, supply or transfer of such goods, or their import into the union until 30 september 2023 and applies only to those goods that were already physically located in russia at the time when the relevant prohibitions entered into force. aligns the member states’ reporting obligation on deposits exceeding eur 100 000 from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia, with the similar obligations that already exist for the other types of deposits. extends the existing prohibition on the provision of certain services to the russian federation and to legal persons, entities or bodies established in russia by banning the provision of advertising, market research and public opinion polling services, as well as product testing and technical inspection services. further clarifies and amends the exemptions to the import ban on steel products that either originate in russia or have been exported from russia. council regulation (eu) 2022/2475 (regulation 2475) 16 december 2022 regulation 269 on publication date introduces a new deadline, 17 june 2023, for the derogation allowing divestments by sberbank with a view to winding down its operations. extends to the 2 newly listed entities (being credit bank of moscow and dalnevostochny bank) the derogation from the asset freeze and from the prohibition to make funds and economic resources available, in order to allow the termination of operations, contracts, or other agreements, previously concluded with those entities. introduces a new derogation allowing the unfreezing assets of, and to make funds and economic resources available to, certain individuals who held a significant role in international trade and agricultural and food products, including wheat and fertiliser, prior to their listing. extends the deadline for certain general derogations. council implementing regulation (eu) 2022/2476 (regulation 2476) 16 december 2022 regulation 269 on publication date adds a further 141 individuals and 49 entities to the asset freeze list under regulation 269, including credit bank of moscow and dalnevostochny bank. council decision (cfsp) 2022/2477 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2476 above. council decision (cfsp) 2022/2478 16 december 2022 decision 512 on publication date equivalent to those listed under regulation 2474 above. council decision (cfsp) 2022/2479 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2475 above. council implementing regulation (eu) 2023/192 (regulation 192) 30 january 2023 regulation 269 on publication date adds 1 iranian entity to the asset freeze list under regulation 269 due to its involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2023/193 30 january 2023 decision 145 on publication date equivalent to those listed under regulation 192 above. council regulation (eu) 2023/426 (regulation 426) 25 february 2023 regulation 269 on publication date extends to certain newly-listed banks (rosbank, tinkoff bank and alfa bank) certain licensing grounds for derogations from the asset freeze, and to allow the processing of payments by the jewish claims conference through one of them. extends the deadline to apply for the disposal or the transfer of securities by the national settlement depository (nsd), and which are currently or were previously controlled by vtb bank. introduces a derogation allowing for the termination of operations, contracts or other agreements with limited liability company “commercial vehicles - gaz group”, and extended by three months the deadline for the derogation to allow the sale and transfer of proprietary rights in a legal person, entity or body established in the eu owned by a listed natural or legal person, entity or body. introduces a requirement that natural and legal persons, entities and bodies should supply to the national competent authorities detailed information on funds and economic resources which have been frozen or should have been treated as frozen, as well as information on funds and economic resources belonging to, owned, held or controlled by listed natural or legal persons, entities or bodies which were subject to any move, transfer, alteration, use, access, or dealing shortly before the listing. introduces a requirement that central securities depositories, due to their systemic importance for the functioning of securities markets, should provide the relevant information to the member state concerned and simultaneously to the commission. specifies the type of information to be provided to national competent authorities, which authorities should then transmit that information to the commission, with specific adaptations in the case of criminal proceedings. provides for deferred application of the more detailed reporting requirements, in order to allow time to adapt. clarifies that member states and the relevant natural and legal persons, entities and bodies are required to cooperate with the commission in any verification of such information, and that the commission should be able to request any additional information, while informing the member state concerned of such request. council regulation (eu) 2023/427 (regulation 427) 25 february 2023 regulation 833 on publication date adds 96 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed. adds several iranian entities to the list of natural and legal persons, entities and bodies subject to restrictive measures under decision 512, taking into account the direct connection between iranian manufacturers of unmanned aerial vehicles and the russian military and industrial complex and the concrete risk that certain goods or technology are used for the manufacture of military systems that contribute to russia’s war of aggression against ukraine. extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding rare-earths and compounds, electronic integrated circuits and thermographic cameras, among others. extends the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. prohibits the transit via the territory of russia of dual-use goods and technology and of arms exported from the eu in order to minimise the risk of circumvention of the restrictive measures. extends the suspension of broadcasting licences in the eu of russian media outlets under the permanent control of the russian leadership and the prohibition against broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of such media outlets in the eu, or directed at the eu. the measures should be maintained until the aggression against ukraine is put to an end, and until the russian federation, and its associated media outlets, cease to conduct propaganda actions against the eu and its member states. those measures do not prevent the media outlets and their staff from carrying out activities in the eu other than broadcasting, such as research and interviews. restricts the possibility to hold any posts in the governing bodies of european critical infrastructures and critical infrastructures identified or designated as such under national law. imposes a prohibition on providing gas storage capacity in the eu to russian nationals, natural persons residing in russia or legal persons or entities established in russia. introduces an obligation for aircraft operators to notify non-scheduled flights to their competent authorities the member state concerned should immediately inform other member states, the network manager and the commission where it does not clear such a flight. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. it also extends the duration of the period in which the competent authorities of the member states may authorise transactions which are necessary for the divestment and withdrawal by those russian state-owned entities from eu companies. requires that natural and legal persons, entities and bodies supply to the competent authorities of the member states and simultaneously to the commission information on the management of reserves and assets of the central bank of russia, which they hold or control or are a counterparty to. it is also appropriate to specify the type of information to be provided and how this should be treated and used to ensure the uniform application of this reporting obligation. it should also be clarified that member states and the relevant natural and legal persons, entities and bodies must cooperate with the commission in any verification of such information and that the commission may request any additional information, while informing the member state concerned of such request. in order to allow time to adapt, the new rules provide for deferred application of the new reporting requirements. introduces a temporary derogation from the prohibition on providing accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services, architectural and engineering services, legal advisory services and it consultancy services. in order to facilitate an expeditious exit from the russian market, this derogation is temporary and limited in scope, enabling until 31 december 2023 the continuation of the provision of services to and for the exclusive benefit of the legal persons, entities or bodies resulting from the divestment. additionally, the competent authorities of the member states should ensure that the services are not provided to the government of russia or benefit military end-users or have a military-end use. provides for certain exemptions for eu operators to provide pilot services to vessels in innocent passage as defined by international law which are necessary for reasons of maritime safety. provides for rules on the release by the customs authorities of the member states of goods which are physically in the eu and which had already been presented to customs authorities when they became subject to such restrictions. authorises member states to release goods already brought into the eu in the past. the competent authorities of the member states should ensure that the release of the goods and any payment related thereto comply with the provisions and objectives of eu restrictive measures. similarly, any decision not to release such goods should comply with those objectives and ensure, among others, that the goods are not returned to russia. makes certain technical corrections in the operative text of decision 512. council implementing regulation (eu) 2023/429 (regulation 429) 25 february 2023 regulation 269 on publication date adds a further 87 individuals and 34 entities to the asset freeze list under regulation 269, including most significantly rosbank, tinkoff bank and alfa bank. council implementing regulation (eu) 2023/430 (regulation 430) 25 february 2023 regulation (eu) 2020/1998 on publication date designates the wagner group and three of its members involved in serious human rights violations in different parts of the world. adds 8 individuals and 7 entities in the list of natural persons, legal persons, entities and bodies subject to restrictive measures under regulation (eu) 2020/1998. council decision (cfsp) 2023/432 25 february 2023 decision 145 on publication date equivalent to those listed under regulation 426 above. council decision (cfsp) 2023/433 25 february 2023 decision 1999 on publication date equivalent to those listed under regulation 430 above. council decision (cfsp) 2023/434 25 february 2023 decision 512 on publication date equivalent to those listed under regulation 427 above. council implementing regulation (eu) 2023/419 (regulation 419) 27 february 2023 regulation 765 on publication date renews the restrictive measures imposed on belarus until 28 february 2024. amends the entries relating to 21 individuals and 2 entities included in the list of natural and legal persons, entities and bodies subject to restrictive measures under regulation 765. council decision (cfsp) 2023/421 27 february 2023 decision 642 on publication date equivalent to those listed under regulation 419 above. council regulation (eu) 2023/1214 (regulation 1214) 23 june 2023 regulation 833 on publication date prohibits the transit of goods and technology suited for use in aviation or space industry and jet fuel and fuel additives, exported from the eu to third countries via russia. allows for appropriate individual measures such as designations or trade restrictions, to be adopted to address the involvement of third-country operators facilitating circumvention. introduces the possibility of last-resort measures restricting the sale, supply, transfer or export of sensitive dual-use goods and technology, or goods and technology that might contribute to the enhancement of russia’s military, technological or industrial capacities or to the development of russia’s defence and security sector to third countries used for circumvention. adds 87 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, certain entities from third countries involved in the circumvention of trade restrictions, and certain entities involved in the development, production and supply of electronic components for russia’s military and industrial complex. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which contribute to the development or production of russia’s military systems, including electronic components, semiconductor materials, manufacturing and testing equipment for electronic integrated circuits and printed circuit boards, precursors to energetic materials and precursors to chemical weapons, optical components, navigational instruments, metals used in the defence sector and marine equipment. extends the list of restricted firearms, their parts, essential components and ammunition, and adds other types of arms. imposes further restrictions on exports of goods which could contribute to the enhancement of russian industrial capacities. prohibits the sale, licence or transfer in any other way of intellectual property rights or trade secrets used in connection with restricted goods. extends the suspension of the broadcasting licences in the eu of five russian media outlets under the permanent control of the russian leadership, and the prohibition against broadcasting their content. extends the prohibition on the transport of goods by road in the eu by trailers and semi-trailers. prohibits access to ports and locks in the territory of the eu by vessels engaged in ship-to-ship transfers where the competent authorities have reasonable cause to suspect that a vessel is in breach of the ban on importing seaborne russian crude oil and petroleum products into the eu or is transporting russian crude oil or petroleum products purchased above the price cap agreed by the price cap coalition. prohibits access to ports and locks in the territory of the eu by vessels which competent authorities have reasonable cause to suspect of illegally interfering with, switching off or otherwise disabling their shipborne automatic identification systems (ais) when transporting russian crude oil and petroleum products. that prohibition does not apply in circumstances where the shipborne ais can be legitimately turned off in accordance with international agreements, rules or standards that provide for the protection of navigational information, such as navigation through high-security-risk waters. ends the temporary derogation granted to germany and poland for the supply of crude oil by pipeline from russia through the northern section of the druzhba oil pipeline. the import of oil which originates in kazakhstan or another third country and is transiting through russia via the druzhba oil pipeline is not prohibited. introduces derogations from the prohibitions on the sale, supply, transfer or export directly or indirectly to any natural or legal person, entity or body in russia or for use in russia of certain goods or technology, on the provision of related financing or financial assistance, technical assistance, brokering services or other services, or on the provision of auditing services, engineering services, legal advisory services, technical testing and analysis services which are strictly necessary for that purpose, subject to strict conditions to avoid the risk of circumvention. extends prohibition on providing transferable securities to financial instruments denominated in any currency. introduces a derogation from the prohibition to provide certain services to russian entities required for the setting-up, certification or evaluation of a firewall removing the control exercised by a listed person over the assets of a non-listed eu entity which the listed person owns or controls. clarifies the evidence required for importation of iron and steel products processed in a third country incorporating iron and steel products originating in russia. introduces clarifications regarding the competent authorities which receive notifications of non-scheduled flights between russia and the eu. extends the deadline for the application of a temporary derogation from the prohibition on providing certain services, with the aim of further facilitating divestment from the russian market by union operators. introduces a temporary derogation from the prohibition on providing legal advisory services to legal persons, entities or bodies established in russia. the competent authorities of the member states may authorise the provision, until 31 march 2024, of legal services which are mandatory, under the national legislation of the member state, for such divestments to be completed. adds switzerland to the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. council regulation (eu) 2023/1215(regulation 1215) 23 june 2023 regulation 269 on publication date introduces a further criterion for the asset freeze listing to allow the designation of legal persons, entities or bodies operating in the russian it sector with a licence from federal security service of the russian federation (fsb) or the russian ministry of industry and trade. amends an existing listing criterion regarding the circumvention of eu sanctions, or significant frustration of eu sanctions by third country operators, including instances where the main activity of a third country operator consists of purchasing restricted goods in the eu that reach russia, the involvement of russian individuals or entities, the recent creation of a company for purposes related to restricted goods reaching russia, or a drastic increase in the turnover of a third country operator involved in such activities. introduces further derogations from the asset freeze to allow for divestment from russian companies and the disposal of certain types of securities held with vtb bank and national settlement depository (nsd). introduces a derogation allowing the provision of services required for the establishment of a firewall removing the control by a listed person over the assets of an eu entity. allows for the provision of pilot services in specific circumstances to safeguard maritime safety. insertion of certain clarifications in the provision on information sharing between competent authorities and regarding the respect of the confidentiality of the communications between lawyers and their clients in the context of reporting obligations. introduces a derogation allowing the release of frozen funds belonging to alexey alexandrovits mordashov after having determined that such funds are necessary for the completion of transactions of a joint venture. introduces a derogation allowing the release of frozen funds for certain banks when such funds are necessary for the purchase, import or transport of agricultural and food products, namely the following entities, bank rossiya, promsvyazbank, veb.rf, otkritie fc bank, novikombank, sovcombank, vtb bank, sberbank, credit bank of moscow, jsc ‘dalnevostochniy bank’, jsc ural civil aviation factory, alfa-bank js, public joint-stock company rosbank, mrb bank and cmr bank. council implementing regulation (eu) 2023/1216(regulation 1216) 23 june 2023 regulation 269 on publication date adds a further 71 individuals and 33 entities to the asset freeze list under regulation 269, including most significantly mrb bank and cmr bank. council decision (cfsp) 2023/1217 23 june 2023 decision 512 on publication date equivalent to those listed under regulation 1214 above. council decision (cfsp) 2023/1218 23 june 2023 decision 145 on publication date equivalent to those listed under regulation 1215 above. council implementing regulation (eu) 2023/1591 (regulation 1591) 3 august 2023 regulation 765 on publication date adds a further 38 individuals and 3 entities from belarus to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765. council implementing decision (cfsp) 2023/1592 3 august 2023 decision 642 on publication date equivalent to those listed under regulation 1591 above. council regulation (eu) 2023/2873 (regulation 2873) 18 december 2023 regulation 269 on the day following that of its publication date extends the listing criteria to cover natural or legal persons, entities or bodies benefitting from the compulsory transfer of ownership of, or control over, entities established in russia that were previously owned or controlled by eu entities. sets out the conditions on which the council is able to retain the name of a deceased person on the asset freeze list under particular circumstances. introduces a derogation to allow for the release of frozen funds or economic resources, in cases where a member state deprives a listed person of funds or economic resources belonging to, or owned by or controlled by, it, and for making funds and economic resources available to such person for compensation to be paid. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the sale or use of shares in, or assets of, an entity established in russia where the ownership or control by an eu legal person of that entity has been compulsorily transferred by the russian government. that derogation would enable, among others, the payment of agreed adequate compensation to eu legal persons. extends the deadline applicable to the existing derogation allowing the processing of payments by the jewish claims conference until 31 december 2024 through alfa-bank jsc and introduces a derogation to allow for certain payments as an indemnity or benefit for the materialisation of a risk involving a newly listed entity. introduces a temporary derogation from the asset freeze and the prohibition on making funds and economic resources available to allow the sale and transfer of proprietary rights directly or indirectly owned by certain listed persons (namely petr aven, mikhail fridman, gennady timchenko, german khan, alexey kuzmichev, igor kesaev, boris rotenberg, arkady rotenberg, as well as certain legal entities) in a legal person, entity or body established in the eu. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the termination of contracts concluded with a newly listed entity. extends to a newly listed alfastrakhovanie, an insurance company, the existing derogation currently applicable to certain listed banks under certain circumstances. makes technical amendments in the operative text, defines the scope of certain reporting obligations and introduces an obligation for national competent authorities of member states to designate in accordance with national legislation the national authorities competent to identify and trace, where appropriate, funds and economic resources belonging to, or owned, held or controlled by, listed natural or legal persons, entities or bodies, with a view to preventing or detecting instances of a breach or circumvention, or attempts at a breach or circumvention, of regulation 269. council regulation (eu) 2023/2878(regulation 2878) 18 december 2023 regulation 833 on the day following that of its publication date adds 29 new entities to the list of legal persons, entities and bodies supporting russia’s military and industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemicals, lithium batteries, thermostats, dc motors and servomotors for unmanned aerial vehicles, machine tools and machinery parts. introduces a list of partner countries, being swtizerland and norway, which apply a set of restrictive measures on imports of iron and steel and a set of import control measures. it also extends certain wind-down periods for the import of specific steel products. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. prohibits the transit via the territory of russia of certain goods and technology which could contribute in particular to the enhancement of russian industrial capacities, exported from the eu. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. provides for an exemption for the entry of cars into the eu for specific circumstances. introduces a derogation enabling the granting of loans or credits to entities operating in the russian energy sector which are subject to the transaction ban provided for in regulation 833, under the conditions provided for therein. imposes a prohibition on the direct or indirect import, purchase or transfer of diamonds from russia. that prohibition applies to diamonds originating in russia, diamonds exported from russia, diamonds transiting russia and russian diamonds when processed in third countries other than russia. the prohibition applies to non-industrial natural and synthetic diamonds, as well as diamond jewellery, as of 1 january 2024, and includes a progressive phasing-in, from 1 march 2024 until 1 september 2024, of an indirect import ban on russian diamonds when processed in third countries other than russia, including jewellery incorporating diamonds originating in russia. prolongs by an additional year specific derogations from the prohibition on imports from russia of crude oil and petroleum products in order to ensure the security of supply of certain member states. introduces a requirement that itemised price information for ancillary costs, such as insurance and freight, be shared upon request throughout the supply chain of russian oil trade. competent authorities can request that information from any actor, regardless of their place in the supply chain, at any time, in order to verify compliance with the price cap mechanism. provides for a notification obligation for the sale of tankers to any third country and a derogation from the prohibition on the sale of tankers to russian persons and entities, or for use in russia. this obligation applies to the owner of a tanker who is a national of a member state, to a natural person residing in a member state, and to a legal person, entity or body which is established in the eu. the owner, or anyone acting on his or her behalf, should notify the competent authorities of any such sale concluded since 5 december 2022 and provide all the necessary details. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2024 to ensure japan’s energy security needs. includes a ban on russian nationals or natural persons residing in russia from owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing crypto-asset wallet, account or custody services to russian persons. extends the existing prohibition on the provision of services to also include the provision of software for the management of enterprises and software for industrial design and manufacture, subject to appropriate exemptions and derogations. imposes certain reporting requirements for the transfer of funds out of the eu made by entities established in the eu, including special purpose entities, whose proprietary rights are owned by entities established in russia, by russian nationals or by natural persons residing in russia. requires that exporters contractually prohibit re-exportation to russia and re-exportation for use in russia of certain specific sensitive goods and technology. council implementing regulation (eu) 2023/2875 18 december 2023 regulation 269 on publication date adds a further 61 individuals and 86 entities to the asset freeze list under regulation 269, most notably including alfastrakhovanie group, the insurance arm of alfa bank. council decision (cfsp) 2023/2871 18 december 2023 decision 145 on publication date equivalent to those listed under regulation 2873 above. council decision (cfsp) 2023/2874 18 december 2023 decision 512 on publication date equivalent to those listed under regulation 2878 above. council decision (cfsp) 2024/195 3 january 2024 decision 145 on publication date adds pjsc alrosa and its ceo, pavel alekseevich marinychev, to the asset freeze list under decision 145. council regulation (eu) 2024/745 (regulation 745) 23 february 2024 regulation 833 on the day following that of its publication date adds 27 russian and third country entities to the list of legal persons, entities and bodies associated to russia’s military-industrial complex set out in annex iv of regulation 833.expands the list of controlled items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding components for the development and production of unmanned aerial vehicles.imposes further restrictions on exports of goods which contribute in particular to the enhancement of russian industrial capabilities.adds the united kingdom to the list of partner countries for the iron and steel imports. these partner countries apply a set of restrictive measures on imports of iron and steel and a set of import control measures that are substantially equivalent to those regulation 833. council implementing regulation (eu) 2024/753 (regulation 753) 23 february 2024 regulation 269 on publication date adds a further 106 individuals and 88 entities to the asset freeze list under regulation 269. council decision (cfsp) 2024/746 23 february 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 745 above. council decision (cfsp) 2024/747 23 february 2024 decision 145 on publication date equivalent to those listed under regulation 753 above. council regulation (eu) 2024/1428 (regulation 1428) 17 may 2024 regulation 833 on the day following that of its publication date introduces measures to suspend broadcasting activities within the union or directed at the union by certain media outlets listed in the annex to regulation (eu) 2024/1428. council regulation (eu) 2024/1485 (regulation 1485) 27 may 2024 n/a. new measure on publication date provides for the freezing of funds and economic resources of, and the prohibition to make funds and economic resources available to, natural or legal persons, entities or bodies, certain designated natural or legal persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. these restrictions largely mirror those of regulation 269 in substance.provides for certain sectoral restrictions on exporting equipment, technology or software, which might be used for internal repression, as well as items intended primarily for use in the monitoring or interception of information security and telecommunication and the provision of related technical assistance, brokering services, financing or financial assistance. council decision (cfsp) 2024/1484 27 may 2024 n/a. new measure on publication date provides for a travel ban on certain designated natural persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. contains other measures equivalent to those listed under regulation 1485. council implementing regulation (eu) 2024/1488 (regulation 1488) 27 may 2024 regulation 1485 on publication date adds 19 individuals and 1 entity to the asset freeze list under regulation 1485. council implementing regulation (eu) 2024/1493 (regulation 1493) 27 may 2024 regulation 269 on publication date adds a further 2 individuals and 1 entity to the asset freeze list under regulation 269. council decision (cfsp) 2024/1508 27 may 2024 decision 145 on publication date equivalent to those listed under regulation 1493 above. council regulation (eu) 2024/1739 24 june 2024 regulation 269 on publication date introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. clarifies that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. introduces a provision to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them, provided that the member state national or company concerned does not have effective access to remedies under the relevant jurisdiction. introduces a new reporting obligation on member states to report penalties imposed for violations of the restrictive measures provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties. ensures that any document held by the council, the commission or the high representative of the union for foreign affairs and security policy for the purpose of ensuring the enforcement of the measures set out regulation 269, or of preventing the violation or circumvention thereof, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. that protection also applies to the joint proposals from the high representative of the union for foreign affairs and security policy and the commission for the amendment of regulation 269 and to any preparatory documents related to them. council regulation (eu) 2024/1745 24 june 2024 regulation 833 on the day following that of its publication date amends the prohibition to land in, take off from or overfly the territory of the eu so that it also applies to any aircraft which is used for a non-scheduled flight and with regard to which a russian natural or legal person, entity or body is in a position to effectively determine the place or time of its take-off or landing. also amends the same prohibition to introduce an exemption for certain aircraft when used for private, non-corporate flights carried out within eu territory and airspace for recreational or training purposes. introduces an obligation for operators to provide, for non-scheduled flights, upon request of the competent authorities of the member state of departure, destination or overflying, information needed for the purpose of verifying compliance with the flight ban, including information about ownership of the aircraft and, where reasonable grounds to suspect circumvention of the flight ban exist, about passengers. amends the prohibition on the transport of goods by road within the territory of the eu, including in transit. eu operators which are owned for 25 % or more by a russian natural or legal person should be prohibited from becoming a road transport undertaking or from transporting goods by road in the eu, including in transit. clarifies that rough diamonds imported from russia prior to 1 january 2024 and polished diamonds imported from russia or manufactured before 1 march 2024 or 1 september 2024, depending upon the weight of the diamond, are not covered by the diamond ban. also amends the ban on russian diamonds in order to enable the temporary import or export of jewellery for repairs, auctions and trade fairs and amends the scope of application and the date of entry into force of the requirement to provide traceability-based evidence. provides that the indirect import ban on russian diamonds processed in third countries other than russia, is temporarily not to apply to jewellery incorporating such diamond. prohibits reloading services in the territory of the eu for the purposes of transshipment operations where such services are used to transship russian lng, except in the case of such transshipments to member states. prohibits new investment and the provisions of goods, technology and services for the completion of lng projects.introduces import restrictions on russian lng through union lng terminals that are not connected to the interconnected natural gas system. introduces a sectoral ban prohibiting access to member states’ ports and locks as well as certain services related to maritime transport for vessels which contribute to russia’s ability to wage war against ukraine. clarifies the scope of the port access ban for russian-flagged vessels and adds a derogation. introduces a prohibition on purchasing, importing, transferring or exporting ukrainian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance, where there are reasonable grounds to suspect that the goods have been unlawfully removed from ukraine, along with a prohibition on related services. enables the possibility to subject companies which make use of russian law provisions, which force the satisfaction of claims against assets of eu companies in a foreign jurisdiction, claims which they would otherwise be prohibited from satisfying pursuant to regulation 833 or regulation 269, to a transaction ban. prohibits eu entities which operate outside of russia from directly connecting to the ‘system for transfer of financial messages’ (spfs) or equivalent specialised financial messaging services set up by the central bank of russia, and adds a transaction ban on eu operators with specifically listed entities using that system outside russia. eu entities however are not prohibited from dealing with russian entities which use the spfs, provided that those eu entities do not connect to the spfs themselves. establishes a transaction ban on eu operators with credit and financial institutions as well as crypto assets providers, established outside of the eu, when the council has determined that those entities facilitate transactions that support russia’s defence-industrial base through the export, supply, sale, transfer or transport towards russia of dual-use goods and technology, common high priority items or firearms and ammunition. broadens the existing prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to any legal person, entity or body established in russia or to any legal person, entity or body majority owned by them. creates an exemption to the prohibition to provide certain services to the government of russia or to legal persons, entities or bodies established in russia, for eu nationals who resided in russia before february 2022 and who are employed by subsidiaries of eu and partner countries’ entities. imposes restrictions on accepting applications for registrations in the eu of certain intellectual property rights by russian nationals, natural persons resident in russia and russian companies. in particular, and without prejudice to their procedural rules, intellectual property offices and other competent institutions should not allow the filing of such applications. introduces a prohibition on the acceptance, by political parties, foundations, alliances, non-governmental organisations, including think tanks, and media service providers in the eu, of financing, donations or any other economic benefits or support from russia, whether directly or indirectly. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. provides for member states to report about penalties imposed for violations of restrictive measures. ensures that the documents held by the council, the commission and the high representative of the union for foreign affairs and security policy concerning the enforcement of the restrictive measures set out in regulation 833, or concerning the prevention of the violation or circumvention of those measures, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. introduces provisions to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them. provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties, as appropriate, in accordance with national administrative law or with other relevant national law or rules requires eu operators to undertake their best efforts to ensure that legal persons, entities and bodies established outside the eu that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 833. requires eu operators to contractually prohibit their commercial counterparts in third countries from using, or allowing the use of, the intellectual property rights, trade secrets or material or information protected by intellectual property rights or protected as trade secret transferred to them in connection with common high priority items to be sold, supplied or exported to russia or for use in russia. requires eu operators that are selling, supplying, transferring or exporting common high priority items to third countries, other than the partner countries listed in annex viii regulation 833, to implement due diligence mechanisms capable of identifying and assessing risks of exportation to russia and mitigating such risks. eu operators must also ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. adds 61 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512. also includes on that list certain entities in third countries other than russia that are involved in the circumvention of trade restrictions and that engage in the procurement of sensitive items used for. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. adds five common high priority items to the restrictions on exports of goods. introduces further restrictions on the import of helium. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2025 to ensure japan’s energy security needs. makes certain technical amendments in the operative text and annexes, deleting references to transitional periods which have expired introduces a horizontal exemption from the prohibitions in this regulation for the paks ii nuclear project, with a notification obligation for such activities. expands the lists of partner countries that apply a set of export control measures or a set of restrictive measures on imports of iron and steel and a set of import control measures which are substantially equivalent to those set out in regulation 833. council implementing regulation (eu) 2024/1746 24 june 2024 regulation 269 on publication date adds a further 69 persons and 47 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/1776 24 june 2024 regulation 833/regulation 1428 on the day following that of its publication date provides that the measures in relation to broadcasting in regulation 833 apply from 25 june 2024 in respect of all entities referred to in the annex to regulation 1428 and can be found here. council decision (cfsp) 2024/1738 24 june 2024 decision 145 on publication date equivalent to those listed under regulations 1739 and 1746 above. council decision (cfsp) 2024/1744 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1745 above. council decision (cfsp) 2024/1770 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1776 above. council regulation (eu) 2024/3189 (regulation 3189) 16 december 2024 regulation 269 on publication date introduces a derogation allowing the release of cash balances that are held by central securities depositories and attributable to the nsd. introduces a derogation allowing the release of frozen funds to arkady rotenberg, boris rotenberg and gennady timchenko. council regulation (eu) 2024/3192 (regulation 3192) 16 december 2024 regulation 833 on the day following that of its publication date adds 32 new entities to the list of persons, entities and bodies supporting russia’s military-industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles or missiles. adds further vessels to the list of vessels on which a ban from member states’ ports and locks, as well as a ban on the provision of a broad range of services related to maritime transport, are imposed. adds that certain actions by a central securities depository carried out in good faith do not give rise to liability of any kind on the part of that depository, or of its directors or employees, unless it is proved that the action was a result of negligence. introduces a prohibition on the recognition or enforcement in the union of injunctions, orders, judgments or other court decisions pursuant to or in relation to article 248 of the arbitration procedure code of the russian federation or equivalent russian legislation. makes certain technical amendments to regulation 833, including to extend the deadlines applicable to certain derogations needed for divestments from russia or for member states’ security of supply of certain petroleum products. council implementing regulation (eu) 2024/3177 (regulation 3177) 16 december 2024 article 8a(1) of regulation (ec) no 765/2006 on publication date adds 26 individuals and 2 entities in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 in view of the situations in belarus. council implementing regulation (eu) 2024/3183 (regulation 3183) 16 december 2024 regulation 269 on publication date adds a further 54 individuals and 30 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/3188 (regulation 3188) 16 december 2024 regulation 2642 on publication date adds 16 individuals and 3 entities to the list of natural and legal persons, entities and bodies set out in annex i to regulation (eu) 2024/2642. council decision (cfsp) 2024/3174 16 december 2024 decision 2643 on publication date equivalent to those listed under regulation 3188 above. council decision (cfsp) 2024/3182 16 december 2024 decision 145 on publication date equivalent to those listed under regulation 3189 and regulation 3183 above. council decision (cfsp) 2024/3187 16 december 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 3192 above. council implementing decision (cfsp) 2024/3175 16 december 2024 decision 642 on publication date equivalent to those listed under regulation 3177 above. council regulation (eu) 2025/390 (regulation 390) 24 february 2025 regulation 269 on publication date introduces two further criteria for the listing of natural or legal persons, entities or bodies in relation vessels involved in certain activities or who form part of, supporting, materially or financially, or benefitting from russia’s military and industrial complex. extends an existing divestment derogation to three additional listed individuals. extends the scope of two existing derogations regarding certain transfers of funds and payments. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries as referred to in annex viii of regulation 833 that apply similar restrictive measures. enables the commission to process personal data in relation to the due diligence required from union operators in respect of potential business partners. allows union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages. introduces a best-efforts obligation to union operators undertake such best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 269. further expands on the scope of the best efforts obligation. makes a number of technical amendments in order to ensure the clarity of certain provisions of regulation 269 including those concerning documents held by the union institutions and the processing of personal data. council regulation (eu) 2025/392 (regulation 392) 24 february 2025 regulation 765 on publication date strengthens the prohibition on the export of dual-use goods and technology and of goods and technology which might contribute to the technological enhancement of belarus’s defence and security sector. expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including chemical precursors to riot control agents, software related to computer numerical control machines, chromium ores and compounds and controllers used to guide unmanned aerial vehicles. imposes further restrictions on exports of goods which could contribute to the enhancement of belarusian industrial capacities, such as chemical elements, pyrotechnic articles and combustible materials. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus of machinery and of goods which could contribute, in particular, to the enhancement of belarusian industrial capacities. establishes derogations for the provision of certain goods and machinery necessary for civilian non-publicly available electronic communications networks. introduces further restrictions on the import of primary aluminium, which allows belarus to diversify its sources of revenue, thereby enabling its involvement in the russian aggression against ukraine. imposes a restriction on the sale, supply, transfer, export or provision of software related to oil and gas exploration in order to further restrict the oil and gas exploration and production capacities of belarus and minimise the risk of circumvention of restrictive measures via the territory of belarus. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, licence or transfer in any other way of intellectual property rights or trade secrets related to a software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of belarus located in a member state. expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by belarusian nationals or natural persons residing in belarus. subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities. prohibits the provision of crypto-asset wallet, account or custody services to belarusian persons and residents and includes a prohibition on belarusian nationals or natural persons residing in belarus owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing such services. introduces an exemption from the prohibition on the sale, supply, transfer or export of banknotes denominated in any official currency of a member state to or for use in belarus, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in belarus, under certain conditions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a belarusian natural or legal person. provides for the freezing of funds and economic resources of, and prohibits making funds or economic resources available to, designated persons, entities and bodies. introduces an additional designation criterion which applies to those forming part of, supporting, materially or financially, or benefiting from the military and industrial complex of belarus. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. union operators can seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as result of claims lodged by the entities or persons. union operators can seek damages from certain persons, entities or bodies that own or control the entities or bodies. introduces provisions in relation to the exchange of information and reporting requirements. union operators that are selling, supplying, transferring or exporting such goods to third countries are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to belarus and mitigating such risks. union operators are required to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions. includes technical amendments. council regulation (eu) 2025/395 (regulation 395) 24 february 2025 regulation 833 on publication date extends the suspension of the broadcasting licences in the union of russian media outlets under the permanent control of the russian leadership, and the prohibition on broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of certain media outlets in the union, or directed at the union. adds 53 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512 on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. also includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles (uavs) or missiles. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemical precursors to riot control agents, software related to computer numerical control (cnc) machines, chromium compounds and controllers used to guide uavs. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as chemicals, some plastics and rubber. further extends the list of goods and technology subject to the prohibition on transit via the territory of russia. empowers competent authorities to authorise the sale and export, and related technical assistance, of information security systems, equipment and components, for non-military use and for a non-military end user, after having determined that such goods or technology or the related technical assistance are intended for a civilian non-publicly available electronic communications network, and provided that that network is not the property of an entity that is publicly controlled or with over 50 % public ownership, such authorisations can be granted in particular to providers of specialised financial messaging services. introduces further restrictions on the import of primary aluminium, which generates significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. introduces a new targeted derogation from the prohibition on importing certain items that are strictly necessary for the operation of the druzhba pipeline. limits the application of an exemption to the flight ban on manned aircraft by introducing the need for an authorisation by the competent authorities. extends the flight ban to listed air carriers operating domestic flights within russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to a russian air carrier or for flights within russia, as well as to any entity owned or controlled by such air carrier. imposes further restriction on exports of goods and technology, in particular software related to oil and gas exploration, in order to further restrict russia’s oil and gas exploration and production capacities. provides for a derogation for the sale, supply, transfer or export from slovakia to hungary or from hungary to slovakia of certain petroleum products as listed in annex xxxi to regulation 833 which are obtained from crude oil imported by pipeline. introduces a prohibition on the provision of temporary storage for russian crude oil and petroleum products within the union, irrespective of the purchase price of the oil and of the final destination of those products. clarifies that reloading services for the purposes of transshipment operations of russian lng are allowed if necessary for its transport between ports of the same member state, including from the mainland of a member state to its outermost regions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a russian natural or legal person. entities established in the union before 8 april 2022 and already operating as road transport undertakings should be prohibited from making any changes to their capital structure that would increase the percentage share owned by a russian natural or legal person, entity or body, unless that percentage share remains below 25 % following such a change. extends prohibitions to the completion of crude oil projects in russia, such as the vostok oil project. introduces a derogation from the prohibition that can be granted by a member state that is not connected to the interconnected natural gas system when the lng is purchased, imported or transferred from a terminal located in another member state that is connected to the interconnected natural gas system in order to ensure its energy supply. requires imports of rough diamonds to be accompanied by a certificate in which the country of mining origin or the countries of mining origin are clearly stated. postpones the date of entry into force of the requirement to provide traceability-based evidence for imports of polished diamonds. furthermore, addressing governance issues associated with the traceability system will require ongoing cooperation with the g7 and third countries. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, license or transfer in any other way of intellectual property rights or trade secrets related to that software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of russia located in a member state. introduces a prohibition on any transaction with ports and locks and airports in russia that are used for the transfer of uavs or missiles or related technology or components thereof to russia, or for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices or of other restrictive measures. imposes restrictions on legal persons, entities or bodies established outside russia that use the system for transfer of financial messages of the central bank of russia. introduces a derogation allowing the execution of transactions with a specific entity included in annex xliv to regulation 833 that are necessary for the repayment of guarantees granted by a member state, divestment from russia or the wind-down of business activities in russia, or execution of certain contracts. further extends the transaction ban on credit institutions, financial institutions and entities providing crypto assets services that support transactions in relation to any listed vessel, thus frustrating the prohibition set out in article 3s of regulation 833. imposes restrictions on legal persons, entities and bodies, as listed in annex xlv to regulation 833, established outside of the union that are credit or financial institutions or entities providing crypto assets services involved in transactions that facilitate, directly or indirectly, the circumvention of the prohibitions set out in article 3n of regulation 833. extends the restrictive measures in relation to the provision of specialised financial messaging services to certain russian credit institutions or entities subscribing to financial messaging services or russian subsidiaries of third-country credit institutions, which are relevant for the russian financial and banking system, and are either large and important regional banks, which consequently facilitate regional and federal finances and business, or banks which facilitate significant cross-border payments or banks which are already the subject of restrictive measures imposed by the union or by partner countries. adds a derogation for the acceptance of deposits otherwise restricted for operations necessary for the restructuring or liquidation of a legal person associated with an entity listed in annex i to regulation 269. introduces an exemption from the prohibition on the sale, supply, transfer or export to russia of banknotes denominated in any official currency of a member state, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in russia under certain conditions. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries that apply similar restrictive measures. extends the provision in regulation 833 on recognition of a claim for damages suffered by union operators as a consequence of a decision pursuant to specific russian legislation to those persons who are responsible for issuing that decision. adds to this provision a reference to russian legislation that allows for the corporate rights of foreign holding structures in economically significant russian organisations to be restricted, as well as for the direct foreign ownership in such organisations to be acquired by russian beneficiaries and for them to receive dividends directly. entitles union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as a result of claims lodged by certain entities or person. enables the commission to assist union operators facilitate their due diligence in respect of potential business partners and enables the commission to process personal data for this purpose. union operators that are selling, supplying, transferring or exporting such goods to third countries, other than the partner countries listed in annex viii to regulation 833, are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to russia and mitigating such risks. requires union operators to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies, and replaces exemptions from certain prohibitions by derogations. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions of regulation 833. adds specific references to the applicable russian legislation in order to update some provisions concerning the protection of union operators. includes technical amendments to improve the accuracy of certain provisions of regulation 833 concerning personal data and documents held by the institutions of the union and to improve the linguistic clarity of certain other provisions. council regulation (eu) 2025/398 (regulation 398) 24 february 2025 regulation 263 on publication date prohibits, subject to certain exceptions, the supply to the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia of banknotes denominated in any official currency of a member state. introduces restrictions on the export to the non-government controlled areas of certain goods and technology that are also restricted by regulation 833. prohibits the provision to the non-government controlled areas of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. it also prohibits the provision to the non-government controlled areas of certain software for the management of enterprises and software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and amends the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. requires that union operators undertake their best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation (eu) 2022/263. member states report about penalties imposed for violations of the restrictive measures. clarifies that the protection against liability that is granted to union operators if they did not know, and had no reasonable cause to suspect, that their actions would infringe union restrictive measures cannot be invoked where union operators have failed to carry out appropriate due diligence. council regulation (eu) 2025/401 (regulation 401) 24 february 2025 regulation 692 on publication date prohibits, subject to certain exceptions, the supply to crimea and sevastopol of banknotes denominated in any official currency of a member state. restricts the export to crimea and sevastopol of certain goods and technology that are also restricted by regulation 833. prohibits the provision to crimea and sevastopol of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. prohibits the provision to crimea and sevastopol of certain software for the management of enterprises and of software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and to amend the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. introduces a best-efforts obligation to union operators. introduces reporting obligations for member states in relation to penalties imposed for violations of restrictive measures. council implementing regulation (eu) 2025/389 (regulation 389) 24 february 2025 regulation 269 on publication date adds a further 48 individuals and 35 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/388 24 february 2025 decision 145 on publication date equivalent to those listed under regulation 389 and 390 above. council decision (cfsp) 2025/391 24 february 2025 decision 642 on publication date equivalent to those listed under regulation 392 above. council decision (cfsp) 2025/394 24 february 2025 decision 512 on publication date equivalent to those listed under regulation 395 above. council decision (cfsp) 2025/396 24 february 2025 decision 266 on publication date equivalent to those listed under regulation 398 above. council decision (cfsp) 2025/397 24 february 2025 decision 386 on publication date equivalent to those listed under regulation 401 above. council implementing regulation (eu) 2025/527 (regulation 527) 14 march 2025 regulation 269 on the day following that of its publication date adds further 126 individuals and 36 entities to the asset freeze list under regulation 269. deletes 3 deceased persons, 4 other persons and 3 duplicate entries from the asset freeze list under regulation 269. council decision (cfsp) 2025/528 14 march 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 527 above.

the bermuda monetary authority (bma) published its fee schedule for 2025, applicable to regulated entities operating under various financial services legislation. effective from 1 january 2025, the updated fees are outlined under the fourth schedule of the bermuda monetary authority act 1969. the comprehensive fee structure impacts institutions governed by laws such as the insurance act 1978, digital assets business act 2018, and investment funds act 2006, among others. key highlights for 2025 annual business fees: fees are applicable from 1 january to 31 december 2025. entities holding multiple licenses are required to pay annual business fees for each licence held. penalty fees for late payments: statutory penalties will apply to businesses that fail to meet the payment deadlines, with penalties increasing based on the duration of non-payment. insurance sector fees: the annual fee due is based on the assigned insurer license class as of 1 january 2025. for insurers that are registered under the segregated accounts companies act 2000, the annual business fee is the level of unconsolidated gross premium written. the annual business fee charged will be based on the combined premiums written in both the general account and the segregated accounts, irrespective of the manner in which the gross premium written is presented on the insurer's statutory financial statements. the publication also provides guidance on refunds, fee definitions and the structure for dual licensees. businesses are encouraged to review the complete schedule to ensure compliance and avoid penalties. for full details, access the official fee document here: bma 2025 fees schedule.

on 14 january 2025, the bermuda monetary authority (bma) published a consultation paper on its proposed operational resilience and outsourcing code, supported by the operational resilience and outsourcing guidance notes, aimed at strengthening the financial sector’s ability to manage and recover from disruptions. the framework is designed to integrate into the risk management systems of certain bma-regulated financial institutions, tailored to their business size, nature, and complexity. this initiative seeks to ensure that critical services remain available without interruption, safeguarding business continuity and consumer confidence. stakeholders are encouraged to share their feedback by emailing policy@bma.bm before 14 march 2025. the consultation notice can be found here.

on 6 march 2025, luxembourg’s commission de surveillance du secteur financier (cssf) announced that a streamlined “e-identification” system to replace the current visa procedure for fund prospectuses will be introduced by april 2025. covering ucits, part ii ucis, sicars, and sifs, this modernised system is designed to enhance administrative efficiency while upholding investor protection standards. key features of the new system unique identification number and date: each prospectus will display a distinct identification number (format yyyy/nnnnnn-nnnnnn-n-pc) and e-identification date on its first page. dedicated edesk application: submissions for new or updated prospectuses will transition through the edesk e-identification prospectus platform, equipped to support smoother automation through api integration. simplified procedures for amendments - a significant change accompanies this implementation. amendments not requiring legal authorisation or prior cssf review can now be integrated directly into the prospectus. a detailed guide outlining these amendments, compliance conditions, and faqs will be available via the edesk platform on 20 march 2025. however, the cssf reserves the right to review such changes retrospectively based on its risk-based approach. amendments or requests requiring prior cssf review and approval under current laws will remain subject to existing procedures. benefits for market participants - this initiative reflects the cssf's commitment to modernisation by simplifying processes and promoting efficiency. it delegates greater responsibility to fund governing bodies for regulatory compliance while maintaining robust oversight mechanisms. through the e-identification system, participants in luxembourg’s financial sector can expect a more seamless, transparent process that aligns with industry demands for innovation and operational efficiency. cssf’s communique can be found here.

on 21 january 2025, the european commission sent a letter to the chair of the joint committee of the supervisory authorities (esas) addressing the draft regulatory technical standards (rts) under the digital operational resilience act (dora). the draft rts, submitted by the esas in july 2024, outlined requirements for financial entities when subcontracting ict services supporting critical or important functions. while the european commission acknowledges the draft rts, it has rejected it as it considers that article 5 of the draft rts which concerns monitoring subcontracting chains exceeds the mandate set out in dora. in turn, the european commission deems that article 5 and recital 5 should be removed from the draft rts in order to be within the scope of the mandate set out in dora. the european commission has stated that it intends to adopt the rts once these concerns are taken into consideration and the relevant amendments are undertaken. this decision highlights the commitment to maintain regulatory clarity while reinforcing financial entities’ digital resilience obligations under dora. the official letter can be found here.

on 22 january 2025, the european supervisory authorities (esas) released a q&a guidance prepared by the european commission, clarifying the definition of information and communication technology (ict) services under the digital operational resilience act (dora). the q&a guidance was published by the european insurance and occupational pensions authority (eiopa). broad scope of ict services dora adopts a broad definition of ict services, covering digital and data services provided through ict systems on an ongoing basis. financial entities must assess whether the services they use fall within the scope of article 3(21) of dora, considering clarifications in recital 63 of dora. financial vs ict services where regulated financial services entail an ict component, the financial entity ought to assess whether those services constitute an ict service under dora. in case the outcome is positive, then the related ict service should be considered to predominantly be a financial service. the european commission clarifies that such regulated financial services could be provided by an eu-regulated financial entity or a third-country one. however, standalone ict services provided by financial entities, unrelated to or independent of regulated financial services, fall under dora’s definition of ict services. the same approach applies to ancillary services, depending on their connection to financial services. key takeaway financial entities should carefully assess their ict services under dora and distinguish them from financial services where applicable. for completeness, while this guidance helps clarify existing rules, only the court of justice of the eu has the authority to interpret eu law definitively. for more information, the q&a can be found on eiopa’s official page, here.

on 31 january 2025, the bvi financial services commission (fsc) published a news release summarising key takeaways from its two key international regulatory forums: the meet the regulator forum in hong kong and the bvi financial services round table in london. a central focus of both forums was the new beneficial ownership (bo) regime, emphasising the fsc’s role in maintaining accurate and up-to-date bo information. discussions covered data transparency, operational efficiency, and regulatory compliance, providing vital insights to industry stakeholders. meet the regulator forum – hong kong held on 16 january 2025, the hong kong forum attracted 120 stakeholders from across the asia-pacific region. presentations covered new bo filing obligations, legislative changes, and operational procedures. managing director and ceo kenneth baker reiterated the fsc’s dedication to strengthening ties with asia, describing hong kong as a crucial hub for financial services. key speakers included deputy managing directors brodrick penn and glenford malone, alongside senior application developer siyeeda brewley. live demonstrations of the bo platform were particularly well received, increasing confidence in its functionality. additionally, one-on-one meetings with industry representatives provided valuable feedback on regional challenges and opportunities. bvi financial services round table – london following the hong kong event, the delegation visited london for a round table discussion on 20 january 2025. with over 24 participants from the trust, corporate, and legal sectors, the event provided further insights into the bo platform and regulatory updates. mr baker reaffirmed the fsc’s commitment to supporting industry players, encouraging open dialogue and engagement. the event initiated productive discussions, with attendees offering feedback and seeking clarity on compliance expectations. for more information, the bvi fsc’s news release can be found here.

on 11 february 2025, the british virgin islands government announced that the jurisdiction has secured an investment-grade bbb/a-2 sovereign credit rating from s&p global, with a stable outlook. this significant recognition reflects the bvi’s commitment to robust fiscal management, economic sustainability, and its pivotal role in the global financial services sector. the rating signals trust in the bvi's financial stability and governance. the effectiveness of this rating will help the bvi to lower borrowing costs, enhance infrastructure, and create new economic opportunities for residents and businesses. it also bolsters investor confidence in the jurisdiction, making the bvi a more attractive hub for global financial services and various cross border investments. the government emphasised its commitment to accountability, transparency, and financial stability, stating that the rating reflects the bvi’s solid economic foundation. with this recognition, the bvi strengthens its position as a premier destination for foreign investment, financial services, and international trade, reinforcing its reputation as a globally trusted financial centre. full details can be reviewed in the official press release here.

on 4 february 2025, the cayman islands published several revised financial and corporate laws to improve regulatory clarity, efficiency, and compliance. these updates impact businesses in company management, banking, and anti-money laundering frameworks. limited liability companies act (2025 revision) the revised llc act refines company formation, governance, restructuring, and compliance standards to align with global expectations. full document here limited liability partnership act (2025 revision) and fee regulations these updates clarify partner responsibilities, registration, and dissolution procedures while introducing revised fees for llp registrations and filings. full documents here | fee regulations here banks and trust companies act (2025 revision) this act enhances licensing, governance, risk management and regulatory compliance for banks and trust companies. full details here companies act (2025 revision) and companies management act (2025 revision) the companies act improves company registration, governance, and transparency. the companies management act strengthens licensing and compliance requirements for corporate service providers. full documents here and here mutual funds act (2025 revision) enhancements include stricter licensing, governance, investor protection, and eu-aligned compliance for mutual funds. full document here private funds act (2025 revision) and amendment order the revised private funds act strengthens fund registration, supervision, valuation, and regulatory oversight. the amendment order (2024) enforces these updates from 1 january 2025. full documents here and here anti-money laundering regulations (2025 revision) key updates include stricter customer due diligence (kyc), enhanced record-keeping, regulations for virtual asset service providers, and stronger enforcement measures. full document here businesses should review these updates to ensure compliance with the latest regulatory changes.

on 31 january 2025, the cyprus securities and exchange commission (cysec) announced that the european securities and markets authority (esma) has introduced the common supervisory approach (csa) 2024-25 with respect to the integration of sustainability in firms’ suitability assessment as well as product governance processes and procedures in 2024. this initiative, in collaboration with national competent authorities (ncas), aims to assess how cyprus investment firms (cifs) integrate sustainability considerations into their suitability assessments and product governance processes. key areas of focus client sustainability preferences: evaluating how firms receive information with respect to their clients’ sustainability preferences. investment product categorisation: ensuring that firms classify investment products based on sustainability factors in relation to suitability assessment. investment suitability: examining how a firm ensures that its investment aligns with sustainability objectives, including a portfolio-based approach. target market assessment: assessing how firms describe sustainability-related objectives with respect to investment products. cysec’s role in the csa cysec will conduct on-site visits and desk-based reviews to a number of cifs which provide investment advice and portfolio management to clients within the retail industry. these reviews, covering the period from 2 august 2022 to 31 december 2024, will help cysec identify whether cifs ensure compliance with mifid ii sustainability obligations enhancing also investor protection. cifs must align with the content of the cysec announcement, as adherence to this content will be part of cysec’s supervisory review for the csa 2024-2025. firms should proactively review their processes to ensure compliance with the sustainability obligations under mifid ii. cysec’s press release can be found here.

the cyprus securities and exchange commission (cysec) previously issued a comprehensive policy statement (ps03-2024) (cysec’s policy statement) outlining fees and reporting requirements under the markets in crypto-assets regulation (micar). this policy establishes guidelines for participants engaging in crypto-asset markets across the european union. key highlights of micar micar introduces a unified regulatory framework for crypto-assets that are fungible but not classified as financial instruments. it affects individuals, businesses, and other entities involved in crypto-asset issuance, public offerings, trading, or related services. micar categorises crypto-assets into: asset-referenced tokens (arts): similar to stablecoins and regulated under title iii of micar. e-money tokens (emts): comparable to electronic money, regulated under title iv, and outside cysec’s supervisory scope. other crypto-assets: a residual category regulated under title ii. “significant” arts and emts under micar, face additional requirements, including oversight by the european banking authority (eba). regulated activities under micar initial offerings and admission of crypto-assets to trading. provision of crypto-asset services. authorisation and compliance obligations for art and emt issuers. market abuse prevention and prohibition related to crypto-assets. implementation and fee structure cysec’s policy statement follows a consultation process initiated in june 2024. the fees payable and reporting details have been refined based on industry feedback. cysec’s policy statement provides the feedback received and outlines the applicable fees. cysec has also published supporting level 2 and level 3 regulatory measures on its website, providing detailed guidance. for more information cysec’s press release can be found here and the policy statement can be accessed here.