EU Guidance on Reporting on Outgoing Transfers

April 2024
Region: Europe

The European Union (the “EU”) has adopted new reporting requirements through the newly introduced Article 5r of Regulation 833/2014 (the “Regulation”), targeting legal persons and entities with substantial connections to Russia.

The new requirements will provide national competent authorities (“NCAs”) with greater transparency on the flow of funds related to Russian-owned entities outside the EU, without jeopardising the activities of entities that are (partially) Russian-owned and operating legitimately in the EU. As a result, NCAs will be in a better position to assess whether certain types of transfers pose a risk of non-compliance with Russia-related sanctions and contribute to mapping Russia’s sources of income.