EU Enhances Sanctions Reporting Obligation

Eu’s 12th package of sanctions

European Union has introduced new reporting requirements under Article 5r of Regulation 833/2014. This regulation targets legal persons and entities with substantial connections to Russia, constituting a crucial component of the EU's 12th package of sanctions against Russia.  Following the updated Consolidated FAQs on the implementation of Council Regulation No 833/2014 as of April 12th, the Cyprus Ministry of Finance has additionally released a notice regarding the reporting obligations applicable to all obligated entities.

Reporting Obligation:
Entities fulfilling the criteria outlined below must, as of 1 May 2024, report to the competent authority of the Member State where they are established, within two weeks of the conclusion of each quarter and should submit information related to any transfer of funds exceeding €100,000 out of the EU effected during that quarter, whether through direct or indirect means.

The obligation to report applies to transfers of an amount exceeding, in sum, €100,000 or more made in one or several operations by the same party.
Applicable Entities:
The Reporting Obligation applies to EU legal persons, entities, and bodies whose proprietary rights are, directly or indirectly owned to more than 40% by:
  • a legal person, entity or body established in Russia
  • a Russian national or
  • a natural person residing in Russia
The Cyprus Bar Association has clarified through an announcement issued 17th April 2024 that if any of its members are appointed as officers (director and/or secretary) within the Applicable Entities, those members are obligated to submit relevant report to the Cyprus Ministry of Finance, provided that the aforementioned criteria are met. It is highlighted that any person who violates any of the provisions of the Regulations of the Council of the European Union, is guilty of an offence.
Parallel Reporting for Institutions:
Credit and financial institutions have a parallel reporting obligation for transfers of funds out of the EU exceeding €100,000. This obligation applies to transfers initiated, directly or indirectly, for the EU legal persons, entities, and bodies mentioned above. Reporting must occur within two weeks of the end of each semester, starting from July 1, 2024.
How Bybloserve Management Ltd can assist you?
In alignment with these regulatory developments, Bybloserve reaffirms its commitment to compliance with the new reporting requirements mandated by Article 5r of Regulation 833/2014. We will undertake all necessary actions for companies under our administration to ensure adherence to these standards, demonstrating our dedication to regulatory compliance and lawful operations. Furthermore, our company will proceed with the issuance of invoices as required.

We can provide comprehensive advice and assistance in navigating the reporting procedure outlined in Article 5r. Whether it involves understanding the criteria for reporting, compiling the necessary information, or submitting reports to the competent authorities, our experts are here to support you every step of the way.

If you have any questions or require further clarification regarding Article 5r of Regulation 833/2014, please do not hesitate to reach out to us. We are here to provide you with expert assistance and ensure a seamless compliance process.

Thank you for your attention to this important update. We look forward to continuing our partnership and supporting your business needs.
DISCLAIMER: The information contained herein is provided for general information purposes only and does not constitute and neither shall be construed as legal or other professional advice. Neither Bybloserve Management Limited nor any of its employees accept any liability for any loss arising from relying on the information contained herein.

How can we assist you?

Andriana Efstathiou
Advocate - Legal Consultant

LLB, LLM in Commercial Law
Cyprus Bar Association
+357 24812026
Alexandra Oikonomou
Advocate - Legal Consultant

Cyprus Bar Association
+357 24812190

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