FRANCE Law and Practice Contributed by: William Julié, Amélie Beauchemin and Camille Gosson, WJ Avocats
of Russia’s actions in destabilising the situation in Ukraine, the Council of the EU adopted a general pro - hibition of the provision of legal services to the gov - ernment of Russia or legal persons, entities or bodies established in Russia, as enshrined in Article 5 (n)(2) of Regulation 833/2014. However, at the time, it already provided for some derogations, and others were added by Council Reg - ulation (EU) 2023/1214 of 23 June 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions in destabilising the situation in Ukraine. The most common ones can be found in paragraphs 5, 6, 9 (a) and 9 (b) of Regula - tion 833/2014, as follows: • the provision of services that are strictly necessary for the exercise of the right of defence in judicial proceedings and the right to an effective legal remedy; • the provision of services that are strictly necessary to ensure access to judicial, administrative or arbi - tral proceedings in a member state, as well as for the recognition or enforcement of a judgment or an arbitration award rendered in a member state; and • the provision of services that are strictly neces - sary for the setting up, certification or evaluation of a firewall that removes control, by a sanctioned natural or legal person, over the assets of a non- listed legal person, entity or body incorporated or constituted under the law of a member state, and which is owned or controlled by the former, as long as no further funds or economic resources accrue to the benefit of the listed natural or legal person, entity or body. In December 2022, the Paris Bar ( Ordre des avocats à la Cour de Paris ), supported by the Geneva Bar, filed an action for annulment contesting the ban on pro - viding non‑litigious legal advice to the Russian state and entities in Russia (case T-798/22). By judgment of 2 October 2024, the court dismissed the challenge, holding that Articles 7 and 47 of the Charter of Funda - mental Rights of the EU protect access to legal advice only in judicial, administrative or arbitral proceedings, outside which the ban applies, subject to sufficiently broad exceptions. The applicants appealed before the
CJEU (case C-866/24); the hearing took place on 14 July 2026. The judgment remains awaited. 2.4 Reporting The Council of the EU imposes reporting obligations in its sanctions regimes, whereby such reports are to be made to the national competent authorities. The Council also provides the possibility to address such information directly to the Commission of the EU. In the context of Russia, it has created reporting obli - gations in both its individual and sectoral sanctions regimes. Council Regulation (EU) No 269/2014 of 17 March 2014, concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, provides for reporting obligations in its Articles 8 and 9 that weigh on both persons sanctioned and central securities depositories (CSDs). As such, natural and legal persons, entities and bod - ies sanctioned, and CSDs must: • supply information that would facilitate the imple - mentation of sanctions – eg, on funds and eco - nomic resources frozen as a result of EU restrictive measures or belonging to, owned, held or con - trolled by persons sanctioned that have not been treated as frozen by the persons obliged to do so – to the national competent authority (in France, the Treasury) within two weeks of acquiring this information; • supply information on funds and economic resources belonging to, owned, held or controlled by sanctioned persons that have been moved, transferred, altered, used, accessed or dealt; • report within six weeks from the date of their listing the location of their funds that are to be frozen; and • co-operate with the competent authority in verify - ing such information. Such information must at least identify: • the person owning, holding or controlling the fro - zen funds and economic resources (name, address and VAT registration or tax identification number);
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