Sanctions Reporting

All natural and legal persons must ensure that they are compliant with financial sanctions as soon as they are adopted. To ensure compliance with EU financial sanctions, it is necessary to monitor the EU Financial Sanctions lists.

Compliance with financial sanctions includes, for example conducting ongoing monitoring of transactions and customers.  This is particularly relevant for credit and financial institutions.

What to do if a match or “hit" occurs

In the event that a match or a “hit” occurs against a sanctioned person, entity or body, credit and financial institutions must immediately freeze the account(s) and/or stop the transaction(s) and report the “hit” to the Central Bank of Ireland, using the below Sanctions Return Form, along with other relevant information. This Sanctions Return Form, and relevant information, should be submitted by email to [email protected].

Before submitting the Sanctions Return Form to the Central Bank, credit and financial institutions should take reasonable steps to ensure that the person, entity or body identified is the same person, entity or body as that listed in the relevant sanctions list, for example by verifying the name with other identifying information.  

The Central Bank is obliged to report the information requested in the Sanctions Return Form to the European Commission (via the Department of Foreign Affairs).  Accordingly, in order to comply with the obligation to report frozen accounts/transactions to the Central Bank, it is important that credit and financial institutions ensure that the Sanctions Return Form is fully completed prior to submission.  Incomplete Forms will be returned to the submitter.

Reporting by credit institutions of deposits exceeding EUR 100,000

EU sanctions measures adopted in response to the crisis in Ukraine include provisions that prohibit the acceptance of certain deposits that exceed EUR 100,000, with some exceptions (the “Deposit Prohibition”).  These provisions apply to:

• Russian nationals or natural persons residing in Russia, or legal persons, entities or bodies established in Russia (Article 5b of Council Regulation (EU) 833/2014); and
• Belarusian nationals or natural persons residing in Belarus, or legal persons, entities or bodies established in Belarus (Article 1u of Council Regulation (EU) 765/2006),

if the total value of deposits of the natural or legal person, entity or body per credit institution exceeds EUR 100,000, subject to certain exceptions.

Article 5g of Council Regulation (EU) 833/2014 and Article 1z of Council Regulation (EU) 765/2006 imposes reporting obligations on credit institutions in this regard.  Credit institutions are required to:

1. supply to the national competent authority of the Member State where they are located or to the Commission by no later than 27 May 2022, a list of deposits exceeding EUR 100,000 held by Russian/Belarusian nationals or natural persons residing in Russia/Belarus, or by legal persons, entities or bodies established in Russia/Belarus. They must also provide updates regarding the amounts of such deposits every 12 months.
2. supply to the national competent authority of the Member State where they are located information on deposits exceeding EUR 100,000 held by Russian/Belarusian nationals or natural persons residing in Russia/Belarus who have acquired the citizenship of a Member State or residence rights in a Member State through an investor citizenship scheme or an investor residence scheme.

In order to report this information to the Central Bank, credit institutions should use the reporting templates developed by the European Banking Authority (the "EBA") available on the EBA's website here: EBA revised templates for reporting of deposits subject to Russian and Belarusian economic sanctions. This webpage contains guidance and instructions to follow when completing the EBA reporting templates. The EBA reporting template, and any relevant information, should be submitted by email to [email protected].

The Central Bank is obliged to report the information requested in the EBA reporting template to the European Commission (via the Department of Foreign Affairs).  Accordingly, in order to comply with this obligation, it is important that credit institutions ensure that the EBA reporting template is fully completed prior to submission.

Credit institutions only need to submit the EBA reporting template to the Central Bank if the deposits that are held by it exceed EUR 100,000. For example, if a person has a deposit balance of EUR 80,000, this does not need to be reported.  Therefore, it is not necessary to submit a “nil” return.

Where a credit institution is not in a position to submit the EBA reporting template by the set deadline, for example, the information is still being collected, it shall notify the Central Bank of the delay, together with the reasons and a proposed alternative deadline.  The Central Bank will consider such submissions on a case-by-case basis. Such correspondence should be sent by email to [email protected].

In this regard,  credit institutions should consider the FAQs published by the European Commission, in particular those relating to “Deposits” as set out on the Commission’s webpage Sanctions adopted following Russia’s military aggression against Ukraine.

Please note that details of deposits of those who are exempt under Article 5b(3) of Council Regulation (EU) 833/2014 and Article 1u(2) of Council Regulation (EC) No 765/2006 do not have to be reported to the Central Bank.

Reporting by listed persons, entities or bodies of funds and/or economic resources located within Ireland

Pursuant to Article 9(2) of Council Regulation (EU) No 269/2014, all natural or legal persons, entities or bodies listed in Annex I to Council Regulation (EU) No 269/2014 (“Annex I”) are obliged to report funds or economic resources within the jurisdiction of a Member State belonging to, owned, held or controlled by them, to the competent authority of the Member State where those funds or economic resources are located. In accordance with Article 9(2) of Council Regulation (EU) No 269/2014, such reporting must be made before 1 September 2022 or within 6 weeks from the date of listing in Annex I, whichever is latest.

Pursuant to Article 9(3) of Council Regulation (EU) No 269/2014, failure to comply with Article 9(2) shall be considered as participation, as referred to in Article 9(1), in activities the object or effect of which is to circumvent the measures referred to in Article 2 of Council Regulation (EU) No 269/2014.

Pursuant to Article 9(6) of Council Regulation (EU) No 269/2014, any information provided or received in accordance with Article 9 shall be used only for the purposes for which it was provided or received.

To facilitate the reporting of this information to the Central Bank, natural or legal persons, entities or bodies listed in Annex I should complete the below Self-Declaration Reporting Form.  This reporting form, and any other relevant information, should be submitted to the Central Bank by email to [email protected].

Pursuant to Article 9(2)(b) of Council Regulation (EU) No 269/2014, natural or legal persons, entities or bodies listed in Annex I shall cooperate with the Central Bank in any verification of the information submitted.

Pursuant to Article 9(4) of Council Regulation (EU) No 269/2014, the Central Bank is obliged to inform the European Commission within two weeks of the information received.  Accordingly, in order to comply with this obligation, it is important that natural or legal persons, entities or bodies ensure that the Self-Declaration Reporting Form is fully completed prior to submission.

In this regard, natural or legal persons, entities or bodies listed in Annex I should consider any guidance and/or FAQs published by the European Commission, as set out on the Commission’s website Sanctions adopted following Russia’s military aggression against Ukraine.

When completing the Self-Declaration Reporting Form, natural or legal persons, entities or bodies listed in Annex I may wish to refer to the “Explanatory Notes” tab in the reporting form for guidance. Any questions arising in connection with the completion or submission of the reporting form should be directed by email to [email protected].

Reporting by natural or legal persons, entities or bodies owning, holding or controlling assets and reserves of the Central Bank of Russia

Pursuant to Article 5a(4a) of Council Regulation (EU) No 833/2014, natural and legal persons, entities and bodies, including the European Central Bank, national central banks, financial sector entities, insurance and reinsurance undertakings, central securities depositories, and central counterparties shall provide, no later than two weeks after 27 April 2023, to the competent authority of the Member State where they are resident or located, and simultaneously to the European Commission, information on the assets and reserves referred to in Article 5a(4) which they hold or control or are a counterparty to. Such information shall be updated every three months and shall at least cover the following:

1. Information identifying the natural or legal persons, entities or bodies owning, holding or controlling such assets and reserves, including the name, address and VAT registration or tax identification number;
2. The amount or market value of such assets and reserves at the date of reporting and at the date of immobilisation;
3. Types of the assets and reserves, broken down according to the categories set out in points (i) to (vii) of Article 1(g) of Council Regulation (EU) No 269/2014,as well as crypto-assets and other relevant categories, and an additional category corresponding to economic resources within the meaning of Article 1(d) of Council Regulation (EU) No 269/2014. For each of those categories, and where available, relevant features, such as quantity, location, currency, maturity and contractual conditions between the reporting entity and the asset owner shall be indicated.

Pursuant to Article 5a(4b), where the reporting natural or legal person, entity or body has established an extraordinary and unforeseen loss or damage to the assets and reserves referred to in paragraph 4a, this information shall be reported immediately to the competent authority of the relevant Member State and transmitted simultaneously to the European Commission.

To facilitate the reporting of this information to the Central Bank, the Central Bank of Russia reporting template should be used.  This reporting template, and any other relevant information, should be submitted to the Central Bank by email to [email protected]. As provided by Article 5a(4a) of Council Regulation (EU) No 833/2014, this reporting template should be submitted simultaneously to the European Commission.  The common template replaces the template previously published by the Central Bank of Ireland.

In this regard, please refer to the European Commission’s Frequently Asked Questions concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it, dated 26 April 2023.  

Reporting of movements of funds and economic resources two weeks prior to listing of a designated person under Council Regulation (EU) No 269/2014

Article 8(1)(a), second indent, of Council Regulation (EU) No 269/2014, as introduced by Council Regulation (EU) 2023/426 of 25 February 2023, provides a reporting obligation on natural and legal persons, entities and bodies to supply immediately “information held on funds and economic resources within Union territory belonging to, owned, held or controlled by natural or legal persons, entities or bodies listed in Annex I and which have been subject to any move, transfer, alteration, use of, access to, or dealing referred to in Article 1(e) or 1(f) in the two weeks preceding the listing of those natural or legal persons, entities or bodies in Annex I, to the competent authority of the Member State where they are resident or located, within two weeks of acquiring this information”.

To facilitate the reporting of this information to the Central Bank, the below reporting form should be used. This reporting form, and any other relevant information, should be submitted to the Central Bank by email to [email protected].

To support compliance with this obligation, on 26 April 2023, the European Commission updated its Frequently Asked Questions concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it, in particular the FAQs on Asset freezes and prohibition to provide funds or economic resources. Consideration should be given to the FAQs prior to submitting the reporting form to the Central Bank.

Reporting by natural or legal persons, entities or bodies established in the EU whose proprietary rights are directly or indirectly owned for more than 40% by a) a legal person or body established in Russia, b) a Russian National or c) a natural person residing in Russia

Pursuant to Article 5r(1) of Council Regulation (EU) No 833/2014, natural and legal persons, entities and bodies, shall provide, as of 1 May 2024, to the competent authority of the Member State where they are resident or located within two weeks of the end of each quarter

• Any transfer of funds exceeding €100,000 out of the EU that they made during that quarter, directly or indirectly, in one or several operations.

The EU Commission have updated the FAQ’s to address queries in relation to this reporting and have also provided a standard reporting template on outgoing transfers under Article 5r of Council Regulation (EU) No 833/2014. To facilitate the reporting of this information to the Central Bank, this Article 5r reporting template should be used.  The reporting template, and any other relevant information, should be submitted to the Central Bank by email [email protected].

• The updated FAQ’s and the standard reporting template can be found at Article 5r updated FAQ's and Reporting Template