Financial sanctions emanate from the EU and the UN and are contained in sanctions lists - see EU and UN headings below. The Central Bank webpages contain an up to date Financial Sanctions Update 2022 where you can see details of EU and UN Security Council updates. Please also visit the page on changes to the Russia/Ukraine Regulations as of 15 March 2022 which contains some useful information. Members must check whether they hold any funds or economic resources for the persons set out in the current sanctions lists.

In relation to Fund Service Providers, the Central Bank issued an industry communication to them on 7 March 2022 on effectively managing risks due to the Russian invasion into Ukraine. The letter sets out Central Bank expectations that Fund Service Providers will take timely action, with heightened precautions, to ensure no breaches of the sanctions occur.
The Central Bank website states that once a person or entity has been sanctioned under EU Financial Sanctions, there is a legal obligation not to transfer funds or make funds or economic resources available, directly or indirectly, to that person or entity.
For general information on sanctions, you can click here to access the Central Bank webpage "Introduction to Financial Sanctions”.  The  Central Bank also has a Financial Sanctions FAQs Booklet (2015) and while it is published for credit and financial institutions, it may answer some of your general queries in relation to sanctions.
 
 
 
 
 
 
 

The Revenue Commissioners have recently published a manual on EU Sanctions in response to the situation in Ukraine. Please click here to access the manual. The manual may be of somewhat limited value as some paragraphs are redacted/not published under FOI legislation.  However, the manual states that the relevant unit to contact is the Prohibitions and Restrictions Unit and the contact email is rcpr@revenue.ie. 

Members should be aware of and adhere to the current trade prohibitions issued by the DETE - see EU Trade Sanctions in Response to Situation in Ukraine - DETE (enterprise.gov.ie). These include those that apply to military-related goods and technology, or financial or technical assistance; and dual use goods and technology.

The Department of Enterprise Trade and Employment has published a Guidance Note: EU Trade Sanctions in response to Russia’s aggression against Ukraine dated 22 March 2022 and you can click here to access it.

The Department of Enterprise, Trade and Employment is the competent authority responsible for enforcing trade-related sanctions. Queries regarding trade sanctions should be directed to the Trade Licensing and Control Unit. They can be contacted by email at exportcontrol@enterprise.gov.ie. or by telephone on +353 1 631 2328.

Please click here for policy information from the Department of Finance on Anti-Money Laundering and Countering the Financing of Terrorism. Paragraph 10 contains information relating to sanctions. Members are reminded that all legal and natural persons are bound by the obligations in the sanctions.

Please click here for the Institute’s  recent news updates on communications from the Irish Department of Finance and see also information under "Europe" heading below.

EU and UN sanctions are implemented in Ireland through EU council decisions and regulations. The regulations are directly applicable in Irish law. In addition, statutory instruments (SIs) are frequently made in order to provide for a domestic offence for breach of the sanctions and for related penalties. A comprehensive list of SIs may be found in the searchable Irish Statute Book, and a number of new regulations in relation to Ukraine and Belarus have been made by the Minister for Finance in recent days.

On 2 March 2022, CCAB issued a joint statement to the profession following recent and ongoing development in Ukraine.  This guidance concentrates on our UK based members’ obligations in relation to sanctions, ethical considerations and obligations under AML legislation.
On 4 March 2022, Chartered Accountants Ireland, together with the other members of CCAB Ireland, issued a joint statement to the profession following recent and ongoing developments in Ukraine. This guidance considers Irish members’ obligations in relation to sanctions, ethical considerations and obligations under AML legislation.

CCAB-I recently issued its updated Anti Money laundering guidance for accountants. While the main focus is general anti money laundering guidance for members and others, there are some paragraphs included in relation to sanctions at 5.2.28. Readers are also reminded that one of the geographical risk factors for potentially higher risk of money laundering or terrorist financing listed in the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 is countries subject to sanctions, embargos or similar measures issued by organisations such as, for example, the European Union or the United Nations.

Members are reminded that the imposition of sanctions may impact on the operation of exclusion clauses (if any) in their Professional Indemnity arrangements and should ensure that they check the current position with their providers.

The Department of Foreign Affairs has information about sanctions here and here in respect of the situation in Ukraine. See here also for general information about sanctions on the DFA website (See information on domestic guidance at the bottom of the page).