Updated Information from the General Secretariat of the Treasury and International Finance to persons and obliged entities to implement international financial sanctions imposed by EU Regulations in connection with the Ukraine conflict (18.04.2022)
Updates on this matter are being published on the Treasury’s website, in the Financial Sanctions sections, in the form of a public notice containing a list of the provisions adopted by the European Union in the framework of a package of international financial sanctions.
This document contains the following information: the consolidated list of subjects and obliged entities to EU international financial sanctions, the EU implementing provisions, as well as the main financial obligations applicable to the private sector. Finally, it includes guidance on the implementation of international financial sanctions at the EU level, and the implementing regulations, in terms of the transfer authorization regime, freezing and blocking, and the release of funds.
Within the obligations for the private sector arising from this package of international financial sanctions are the following:
- Freezing of all funds and economic resources owned, held or controlled by natural and legal persons listed in the annexes.
- No funds or economic resources may not be made available, directly or indirectly, to or for the benefit of natural or legal persons, entities or organisms listed in the Annex.
- Communicate and inform the competent authorities of the above actions, in this case the Subdirectorate for the Inspection and Control of Capital Movements, by e-mail to secretariaicmc@economia.gob.esand with the e-mail subject “Freezes”.
- In transactions by notaries, registrars, lawyers and other independent professionals, in the event of a coincidence with any of the persons included on the list, the transaction must be suspended immediately and the relevant authorities (Sepblac and, where appropriate, the centralized prevention organism) must be informed.
- Not to accept deposits from Russian nationals or natural persons residing in Russia, or from legal persons, entities or bodies established in Russia, if the total value of the deposits of the natural or legal person, entity or body per credit institution exceeds EUR 100 000, unless they are from residents, those funds are intended for humanitarian purposes or are deposits necessary for non-prohibited cross-border trade between the EU and Russia, under the conditions set out in Article 5 of EU Regulation 833/2014.
- It is strictly prohibited to sell, supply, transfer or export euro banknotes to any natural or legal person in Russia. This limitation does not imply prohibition of bank transfers.
In addition, in the section on Financial Sanctions, there is a specific section on Russia‘s circumstances, which includes specific guidelines and procedures, as well as several EU interpretative criteria.