The Council of the European Union on the 27th of June 2019, adopted Council Decision (CFSP) 2019/1108 , extending the Russian sanctions regime until 31 January 2020.
The Russian sanctions, are in place since 31 July 2014 and have repeatedly been extended targeting Russia’s economic, energy, security sectors and the area of dual-use goods.
The sanctions restrict the export and import of arms and related materiel to Russia and from Russia as well as related technical or financial assistance and services.
Furthermore, the sale, supply, transfer or export of all dual-use goods and technology for military use in Russia or for any military end-user in Russia is prohibited.
Most importantly the sanctions prohibit to make or be part of any arrangement or to make new loans or credit with a maturity exceeding 30 days to any legal person, entity or body listed below or to any legal person, entity or body established outside the EU but owned for more than 50% by an entity listed below or to any legal person, entity or body acting on behalf or at the direction of such entity. The list of entities includes:
- VTB BANK
- VNESHECONOMBANK (VEB)
- OPK OBORONPROM
- UNITED AIRCRAFT CORPORATION
- GAZPROM NEFT
Asset Freeze and Trave Restrictions
In addition to the above measures, 170 people and 44 entities are subject to an asset freeze and a travel ban these measures are extended until 15th of September 2019. A list of persons subject to the restrictive measures may be found by following this link.
Under the current circumstances and with the sanctions remaining, EU and international companies doing business in Russia and Ukrainian should exercising caution and undertake enhanced due diligence to ensure compliance with any applicable sanctions regulations.
Enhanced Due Dilligence
With the continues sanctions in place and Cyprus’ service industry heavily reliant on Russian and Ukrainian business, what measures have your organization implemented to ensure compliance with the requirements of the Prevention and suppression of money laundering and terrorist financing as well as the CySEC directive on the prevention and suppression of money laundering?