Sanctions 2025

FRANCE Law and Practice Contributed by: William Julié, Amélie Beauchemin, Camille Gosson and Elena Moreno, WJ Avocats

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 frozen funds and economic resources (name, address, and VAT registration or tax identification number); • the amount/market value of the funds or resources, at the date of reporting and at the date of freezing; and • the types of funds. In its frequently asked questions (FAQs), the Commis - sion explicitly states the objective of such reporting obligations, which is to help ensure that those assets are traced effectively in order to avoid circumvention of sanctions via evasion schemes. The Commission also recalls that non-compliance with such obligations would be treated as a breach of EU sanctions law,

with criminal penalties provided by EU member states being applicable. Regarding sectoral sanctions, Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine also provides for some reporting obligations, as follows: • Natural and legal persons, entities and bodies must “inform within two weeks the competent author - ity of the Member State where they are resident, located, established or incorporated, of all transac - tions for the purchase, import or transfer into the Union of natural gas condensates of subheading CN 2709 00 10 from liquefied natural gas produc - tion plants, originating in or exported from Russia. The reporting shall include information on vol - umes”. • “Central securities depositories concerned shall report to the Commission and to their national supervisory authorities, by 30 June of each year, on the total amount of cash balances, revenues and net profits”. • “Legal persons, entities and bodies established in the Union whose proprietary rights are directly or indirectly owned for more than 40% by: (a) a legal person, entity or body established in Russia; (b) a Russian national; or (c) a natural person residing in Russia, shall, as of 1 May 2024, report to the com - petent authority of the Member State where they are established, within two weeks of the end of each quarter, any transfer of funds exceeding 100 000 euros out of the Union that they made during that quarter, directly or indirectly, in one or several operations”. 3. Recent and Future Legal Developments 3.1 Significant Court Decisions or Legal Developments In the past three years, the most significant legal and judicial developments in France arose from the EU restrictive measures imposed on Russia since the beginning of the invasion of Ukraine in February 2022.

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