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EU Sanctions update: Key information for affected individuals and entities under Russia sanctions

17 Oct 2024
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On 13 September 2024, the Council of the European Union (EU) has issued a number of important notices regarding restrictive measures under Council Decision 2014/145/CFSP and Regulation (EU) No 269/2014, as amended and implemented (EU Sanctions), targeting individuals, entities and bodies involved in actions undermining the territorial integrity, sovereignty and independence of Ukraine.

Here's a summary of the key obligations for those affected.

Continuation of restrictive measures

  • The EU has confirmed the continuation of restrictive measures against individuals and entities listed under the EU Sanctions. These measures involve freezing assets and imposing travel bans.
  • Affected parties can apply to access frozen funds for essential needs or specific payments by contacting the relevant authorities in EU Member States.
  • Affected parties have until 2 November 2024, to request a review of their inclusion on the sanctions list or challenge the decision in the General Court of the European Union.

Data processing and privacy

  • Those affected by the restrictive measures under the EU Sanctions should be aware of how their personal data is being processed.
  • The EU collects personal information, including identification details and any statement or grounds in relation to their listing under the EU Sanctions, to ensure proper implementation of sanctions.
  • Data subjects have the right to access, correct, or delete their information.
  • The data is retained for five years after a person is removed from the sanctions list, the expiration of the validity of the measure or in relation to legal cases before the Court of Justice when a final judgment has been handed down.
  • In some cases, the EU may, subject to certain conditions, share data with international organisations for public interest purposes.

Reporting obligations for sanctioned entities

  • Individuals and entities under the EU Sanctions are required to report any funds or economic resources within an EU Member State belonging to, owned, held or controlled by them, to the national authorities to the competent authority of the EU Member State where those funds or economic resources are located.
  • This report must be made within six weeks of being listed.
  • Cooperation with the authorities is mandatory and failure to comply may be considered an attempt to circumvent the sanctions.

For more information or to submit requests, affected parties can contact the Council of the European Union via email at sanctions@consilium.europa.eu. For data protection concerns, reach out to the Council’s Data Protection Officer at data.protection@consilium.europa.eu.

This set of measures is part of the EU’s ongoing commitment to uphold Ukraine’s sovereignty and respond firmly to actions that threaten its territorial integrity. Compliance with these regulations is crucial for individuals and entities impacted by these sanctions.

Notice C/2024/5571 published to the Official Journal of the EU can be accessed here.

Notice C/2024/5572 published to the Official Journal of the EU can be accessed here.

Notice C/2024/5573 published to the Official Journal of the EU can be accessed here.