Read the CySEC Circular C728
Memo #52-2025
CySEC Circular No: C728
Date: 24/09/2025
Subject: EU Council's Restrictive Measures against Russia due to its military aggression against Ukraine – Article 5h of Regulation (EU) 833/2014
Purpose: To draw the attention of the Regulated Entities to the amendment of Article 5h of Council Regulation (EU) 833/2014.
In Summary:
CySEC has issued the Circular C728 on 23/09/2025 to draw the attention of CIFs, ASPs, UCITS Management Companies, Internally managed UCITS, AIFMs, Internally managed AIFs, Internally managed AIFLNPs, Companies with sole purpose the management of AIFLNPs, Crypto Asset Service Providers and Small AIFMs under Law 81(I)/2020, regarding the amendment of Article 5h of Council Regulation (EU) 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine.
The Circular C728 refers to Article 5h after its amendment.
In accordance with Circular C728, CySEC notes that the EU has widened the scope of the amended Article 5h of Regulation (EU) 833/2014, from a prohibition to provide specialised financial messaging services to the legal persons, entities or bodies listed in Annex XIV, into a full transaction ban with the legal persons, entities or bodies listed in Annex XIV (which now includes a total of 45 Russian banks) or their subsidiaries whose proprietary rights are directly or indirectly owned for more than 50% and are established in Russia.
CySEC also notes that the Regulated Entities are reminded of the importance of studying the Commission Consolidated FAQs, which also cover Article 5h of Regulation (EU) 833/2014.
CySEC calls the Regulated Entities to harmonise the existing measures and procedures in place that are designed and implemented for the detection of actions that are in breach or may potentially be in breach of the provisions of the Restrictive Measures and/or Sanctions, in accordance with the amended Article 5h of Regulation (EU) 833/2014.
Article 5h of Council Regulation (EU) 833/2014 can be found on the following link:
Commission Consolidated FAQs can be found on the following link:
Read the CySEC Circular C728
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