EU Commission Updates FAQs on FDI Screening Regulation (EU) 2019/452
On 14 May 2025, the European Commission published an updated version of its Frequently Asked Questions (FAQs) concerning the implementation of the EU Framework for the Screening of Foreign Direct Investments (FDIs), including guidance on its intersection with the EU’s restrictive measures (sanctions).
This update impacts for all stakeholders engaged in cross-border investments, particularly those involving third-country investors, including from Russia and Belarus.
Key Updates:
- The Commission has revised its FAQs on the implementation of Regulation (EU) 2019/452, which establishes a unified EU framework for screening FDIs that may affect security or public order in the Union. It clarifies the scope, process and key risk indicators for Member States conducting FDI reviews.
- The FAQs reiterate the guidance first issued in April 2022 regarding systematic screening of investments originating from Russia and Belarus. This includes investments involving entities directly or indirectly controlled by the Russian or Belarusian government, those subject to sanctions, or those influenced by geopolitical objectives that may threaten EU security or public order.
- The updated document explicitly outlines how FDI screening mechanisms complement EU sanctions. Notably, investments may be subject to scrutiny even when the investor is not individually sanctioned, if there are broader risks tied to state influence or geopolitical context.
How Can Bybloserve Management Assist You?
We closely monitor regulatory developments within the EU to ensure our clients are fully informed and compliant. Our team can assist with assessing FDI transactions for EU regulatory and sanctions risks, advising on due diligence for foreign investors, reviewing corporate structures for potential FDI screening triggers, and liaising with competent authorities when required.
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.