Sanctions and other useful information in response to crisis in Ukraine

Please see our "In the news" page for recent sanctions news  items .

Please use the tabs on the left hand side of this page for further information (which is being updated regularly ) on Russia sanctions as they relate to Ireland, the United Kingdom, Europe & International and items that are in the news including links to interesting articles .

Sanctions -overview

While these pages focus on the recent sanctions’ regime relating to Russia and Belarus, readers should be aware that legally binding restrictive measures, sanctions ,are not new or exclusive to Russia and Belarus. The EU has over 40 different sanctions regimes in place. Some are mandated by the United Nations Security Council, while others are adopted autonomously by the EU. The EU sanctions map provides comprehensive details of all EU sanctions regimes and their corresponding legal acts, including those regimes adopted by the UN Security Council and transposed at EU level.

Why does this matter to you ?

EU sanctions regulations have direct effect in all Member States of the EU, and, as such, are legally binding on all natural and legal persons in Ireland. Accountants as with all other natural and legal persons must comply with any prohibition issued by Irish competent authorities on sanctions (Central Bank , Department of Enterprise Trade and Employment and Department of Foreign Affairs). It is a criminal offence not to comply with sanctions and firms which do not comply also risk reputational damage.

The Russia sanctions regime

As a result of the Russian invasion of Ukraine in February 2022, focus has intensified on the area of sanctions which are being introduced at an unprecedented pace. These webpages seek to centralise information and resources for members to help them comply with their obligations. The situation on sanctions is fast moving so please check back on the pages for periodic updates.

In Ireland, financial sanctions emanate from the EU and the UN, and are contained in sanctions lists. All natural and legal persons are required to comply with financial sanctions. This requires monitoring the EU and UN lists and taking appropriate action, more details of which are given below.

It is a criminal offence not to comply with sanctions and firms which do not comply also risk reputational damage.

CCAB and CCAB-I Guidance

On 2 March 2022, CCAB issued a joint statement to the profession following recent and ongoing developments in Ukraine.  This guidance concentrates on our UK based members’ obligations in relation to sanctions, ethical considerations and obligations under AML legislation.

On 4 March 2022, Chartered Accountants Ireland, together with the other members of CCAB Ireland, issued a joint statement to the profession following recent and ongoing developments in Ukraine. This guidance considers Irish members’ obligations in relation to sanctions, ethical considerations and obligations under AML legislation.

In March 2022 CCAB-I issued its updated Anti Money laundering guidance for accountants. While the main focus is general anti money laundering guidance for members and others, there are some paragraphs included in relation to sanctions at 5.2.28. Readers are also reminded that one of the geographical risk factors for potentially higher risk of money laundering or terrorist financing listed in the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 is countries subject to sanctions, embargos or similar measures issued by organisations such as, for example, the European Union or the United Nations.

On 9 March 2023 the CCAB-I Insolvency Committee  published Technical Alert 01/2023 Help sheet for Insolvency Practitioners on the impact of Sanctions. This help sheet provides information on the legal obligation not to transfer funds or make funds or economic resources available, directly, or indirectly, to any person or entity that has been sanctioned under EU financial sanctions. It also provides some examples of exposure risks for Insolvency Practitioners and how to mitigate such risks.

Professional Indemnity Insurance Considerations

Members are reminded that the imposition of sanctions may impact on the operation of exclusion clauses (if any) in their Professional Indemnity arrangements and should ensure that they check the current position with their providers.

These pages are provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.

Chartered Accountants Ireland can accept no responsibility for the content on any site that is linked to/from the Institute website. Links are provided in good faith for the potential support of members and students.