Summary of CySEC's Circular C527

Memo #38-2022
CySEC Circular No: C527
Date: 22/08/2022
Subject: EU Council's Restrictive Measures against Russia due to its military aggression against Ukraine – “maintenance and alignment” sanctions package
Purpose: To draw the attention of the Regulated Entities to the amendment of Article 9 of Council Regulation (EU) 2022/1273 of 21 July 2022 for restrictive measures against Russia.

In Summary:
CySEC has issued the Circular C527 on 19/08/2022 to draw the attention of the Regulated Entities to the amendment of Article 9 of Council Regulation (EU) 2022/1273 of 21 July 2022 implementing Regulation (EU) No. 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, as published in the Official Journal of the European Union, dated 21 July 2022.

This Circular C527 includes the Article 9 in its entirety, after its amendment.

The Article 9 refers to a reporting obligation for natural or legal persons, entities or bodies listed in Annex I of Regulation (EU) No. 269/2014 (designated persons), with deadline before the 1st of September 2022 or within 6 weeks of listing in Annex I.

CySEC notes that the Ministry of Finance has issued a relevant announcement, dated 9 August 2022, which includes guidelines on how to disclose the funds or economic resources of designated persons, as well as the relevant disclosure form.

CySEC further notes that the said reporting obligation burdens the designated persons, and therefore, if Regulated Entities submit any disclosure on behalf of a designated person, they should take all appropriate actions/measures to ensure the completeness and accuracy of the said disclosure.

Furthermore, CySEC informs that non-compliance with the reporting obligation to the relevant competent authorities shall be considered, based on the provisions of the Regulation, an attempt to circumvent the restrictive measures.

The Ministry of Finance announcement dated 9 August 2022 can be found on the following link:

Council Regulation (EU) 2022/1273 of 21 July 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine can be found on the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2022:194:FULL&from=EN 

Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine can be found on the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0269&from=EN 

Read the CySEC Circular C527

Read more news at Regulatory News