EU Law and Practice Contributed by: Edward Borovikov, Laurens Engelen, Xiaoyi Tang and Semen Medvedkov, Dentons
2.4 Reporting In the EU, the framework for reporting obligations con - cerning sanctions is designed to ensure adherence to, and effective oversight of, restrictions imposed on certain individuals, entities or countries. These obliga - tions are set out in different sanctions frameworks and vary across different sanctions. The obligations are primarily directed at financial institutions, credit institutions, national central banks, insurance and reinsurance undertakings, central secu - rity depositories and other entities or individuals that might come into contact with sanctioned parties. Who Must Report Financial institutions such as banks, insurance/rein - surance companies and other providers of financial services are required to report specific dealings that may involve sanctioned parties or are subject to peri - odic reporting requirements. Additionally, any com - pany or individual that may possess assets or engage in transactions with sanctioned entities must comply with reporting requirements. To Whom Reports Must Be Made Reports must generally be made to the national com - petent authorities of each EU member state, which are typically the financial regulatory bodies or ministries of finance. Such national competent authorities will usually themselves report this information within the Commission. Reporting Circumstances Entities must report the freezing of funds or economic resources belonging to sanctioned individuals or enti - ties. Legal professionals must ensure that their servic - es to sanctioned parties are compliant with sanctions regimes and may need to report their activities, espe - cially if they suspect a breach of sanctions. In specific sanctions regimes, such as the one targeting Russia, reporting must be done regarding the management of reserves and assets of the Central Bank of Russia and the Russian National Wealth Fund. Credit institutions must also report deposits exceeding EUR100,000 being transferred out of the EU by Russian nationals or entities owned by Russian nationals or entities.
Legal Framework The EU regulations that outline specific reporting obli - gations are spread across diverse sanctions or may arise from member states’ national regulatory or pru - dential rules. Council Regulation (EU) No 833/2014 setting out sectoral sanctions vis-à-vis Russia con - tains specific reporting requirements. Such require - ments are also envisaged under the sanctions regimes for Belarus, Haiti and Iran. 3. Recent and Future Legal Developments 3.1 Significant Court Decisions or Legal Developments Since the proliferation of EU sanction regimes, par - ticularly those targeting Russia and Belarus, the juris - prudence of the Court of Justice of the European Union (CJEU) in sanctions matters has become more complex. CJEU Rulings on Sanctions and Due Process The CJEU is continuously strengthening its position that individuals and entities listed under sanctions must have their rights protected. In practical terms, EU sanctions must adhere to the principles of due process, meaning that individuals and entities target - ed by sanctions have the right to be informed of the reasons for their listing and have access to effective legal remedies. Recently, in Gutseriev v Council (Case T 286/25, May 2026), the General Court annulled the sanctions list - ing of Mikail Safarbekovich Gutseriev, holding that the Council of the European Union failed to demonstrate, on an updated and sufficiently solid factual basis, that at the time of the listing Gutseriev still benefited from or supported President Lukashenko’s regime. Moreo - ver, it held that the Council could not rely on Guts - eriev’s business interests in the commercial property sector to conclude support or benefit from the Bela - rusian regime as that would amount to a presumption that would apply to any businessperson in Belarus. Similarly, in Chevtsov v Council (Case T 528/24, April 2026), the General Court held that Mr Chevtsov’s role as honorary consul of the Philippines in Belarus did
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