Read the CySEC Circular C737
Memo #60-2025
CySEC Circular No: C737
Date: 10/11/2025
Subject: EU Council's Restrictive Measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine – 19th package
Purpose: To remind the Regulated Entities that the European Council adopted the 19th package of Restrictive Measures against Russia.
In Summary:
CySEC has issued the Circular C737 on 07/11/2025 to remind 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, that on 23/10/2025 the European Council adopted the 19th package of Restrictive Measures against Russia.
The 19th package includes further individual listings and numerous economic restrictive measures targeting key sectors of Russia, including energy, finance and the military industrial complex.
With this Circular C737 the CySEC wishes to draw the attention of the Regulated Entities to the inclusion of the definitions of ‘owning’ and ‘controlling’ a legal person, entity or body in Article 1 of Regulation (EU) 269/2014. While the EU Commission has previously provided guidance and best practices on the concepts of ownership and control, the definitions are now set out explicitly in the said regulation. This Circular refers to these definitions.
Furthermore, this Circular refers to the amended paragraph 2 of Article 5b and Article 5ah of the Regulation (EU) 833/2014, via Regulation (EU) 2025/2033.
CySEC notes that the Regulated Entities, which have business relationships that are affected by the prohibitions of paragraph 2 of Article 5ah, are requested to inform CySEC within one month, at the latest, at the email address eu.sanctions@cysec.gov.cy, by providing data/information of the affected business relationships and the applicable actions/measures taken or intended to be taken by the Regulated Entity for compliance with paragraph 2 of Article 5ah.
CySEC calls the Regulated Entities to take into account the Articles’ changes, always in combination with the EU Best Practices and the Commission Consolidated FAQs and implement targeted measures to comply effectively. CySEC further calls the Regulated Entities to review all the changes brought by the 19th package of Restrictive Measures and proceed with relevant actions accordingly.
The Regulation (EU) 2025/2033 can be found on the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202502033
The EU Best Practices can be found on the following link: https://data.consilium.europa.eu/doc/document/ST-11623-2024-INIT/en/pdf
The Commission Consolidated FAQs can be found on the following link: https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/sanctions-adopted-following-russias-military-aggression-against-ukraine/frequently-asked-questions-sanctions-against-russia_en
Read the CySEC Circular C737
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