Page last updated 24 June 2022
Ireland
Competent Authorities
The Central Bank is one of the competent authorities for Ireland in the Annexes to the EU Financial Sanctions Regulations and is responsible for the administration, supervision, and enforcement of relevant aspects of financial sanctions in Ireland. The other Irish competent authorities for EU Restrictive Measures are the Department of Enterprise Trade and Employment which is responsible for the implementation of trade sanctions and the Department of Foreign Affairs which is responsible for foreign policy and representing Ireland internationally.
Links to the following websites provide further detail on information that is relevant in Ireland and which members may find useful.
Irish Central Bank
Financial sanctions emanate from the EU and the UN and are contained in sanctions lists - see EU and UN headings below. There are currently six packages of sanctions which have been adopted by the EU. The Central Bank webpages contain an up to date Financial Sanctions Update 2022 where you can see details of EU and UN Security Council updates. Please also visit the Central Bank's page on changes to the Russia/Ukraine Regulations which contains some useful information . Members must check whether they hold any funds or economic resources for the persons set out in the current sanctions lists. Please see the page also for where on 20 April 2022 the Central Bank provided information on how credit institutions should report information regarding deposits by certain persons linked to Russia/Belarus that exceed EUR 100,000.
In June 2022 the Central Bank issued correspondence to business groups and professional representative bodies including Chartered Accountants Ireland regarding financial sanctions obligations. You can read details of the Central Bank press release and the letter it issued here.
In relation to Fund Service Providers, the Central Bank issued an industry communication to them on 7 March 2022 on effectively managing risks due to the Russian invasion into Ukraine. The letter sets out Central Bank expectations that Fund Service Providers will take timely action, with heightened precautions, to ensure no breaches of the sanctions occur.
The Central Bank website states that once a person or entity has been sanctioned under EU Financial Sanctions, there is a legal obligation not to transfer funds or make funds or economic resources available, directly or indirectly, to that person or entity.
For general information on sanctions, you can click here to access the Central Bank webpage "Introduction to Financial Sanctions”. The Central Bank also has a Financial Sanctions FAQs Booklet (2015) and while it is published for credit and financial institutions, it may answer some of your general queries in relation to sanctions.
Irish Revenue Commissioners
The Revenue Commissioners have published and updated a manual on EU Sanctions in response to the situation in Ukraine. Please click here to access the manual. The manual may be of somewhat limited value as some paragraphs are redacted/not published under FOI legislation. However, the manual states that the relevant unit to contact is the Prohibitions and Restrictions Unit and the contact email is rcpr@revenue.ie.
Revenue has a dedicated website for Ukrainian Nationals which sets out advice for starting a job
https://www.revenue.ie/en/life-events-and-personal-circumstances/moving-to-or-from-ireland/advice-ukrainian-nationals-starting-job-ireland.aspx
In April 2022 Revenue announced concessionary tax treatment of Ukrainian citizens who work remotely in the State for Ukrainian employers. You can read more about this including an e Brief here and an article by Jane Quirke of Grant Thornton in the Institutes news .
In May the Government announced a €400 Recognition Payment for providing accommodation to those fleeing war in Ukraine.
Department of Enterprise Trade and Employment (DETE)
Workplace Relations Commission
Members should be aware of and adhere to the current trade prohibitions issued by the DETE - see EU Trade Sanctions in Response to Situation in Ukraine - DETE (enterprise.gov.ie). These include those that apply to military-related goods and technology, or financial or technical assistance; and dual use goods and technology.
The Department of Enterprise Trade and Employment has published a Guidance Note: EU Trade Sanctions in response to Russia’s aggression against Ukraine .The latest version of it is available to access here.
The Department of Enterprise, Trade and Employment is the competent authority responsible for enforcing trade-related sanctions. Queries regarding trade sanctions should be directed to the Trade Licensing and Control Unit. They can be contacted by email at exportcontrol@enterprise.gov.ie. or by telephone on +353 1 631 2328.
Please also refer to the website of the Workplace Relations Commission which contains information for Ukrainian Nationals on employment rights in Ireland .There is information on the website on employment law in the Ukrainian language and the Russian language.
Department of Finance – Ireland
Please click here for policy information from the Department of Finance on Anti-Money Laundering and Countering the Financing of Terrorism. Paragraph 10 contains information relating to sanctions. Members are reminded that all legal and natural persons are bound by the obligations in the sanctions.
Please click here for some Institute news updates on communications from the Irish Department of Finance. See also more detailed information on "Europe and international" sub page.
EU and UN sanctions are implemented in Ireland through EU council decisions and regulations. The regulations are directly applicable in Irish law. In addition, statutory instruments (SIs) are frequently made in order to provide for a domestic offence for breach of the sanctions and for related penalties. A comprehensive list of SIs may be found in the searchable Irish Statute Book, and a number of new regulations in relation to Ukraine and Belarus have been made by the Minister for Finance in recent months.
The Dept of Finance published the booklet Economic and Financial Impacts of War in Ukraine. It was last updated in April 2022.You can access the booklet here.
Department of Foreign Affairs
The Department of Foreign Affairs has information about sanctions here in respect of the situation in Ukraine. See here also for general information about sanctions on the DFA website (See information on domestic guidance at the bottom of the page).
Department of the Taoiseach
The Department of the Taoiseach has established a webpage where there is information for people on arriving in Ireland, accommodation ,social welfare supports, employment, childcare and education healthcare and how people and community groups can help .
The page also has information for businesses on sanctions ,offers of employment and support and sectoral schemes .
Ireland-Other Information
Under Irish law you can exchange your driving licence issued by the licensing authority of Ukraine for an Irish one provided you have permission to remain in Ireland under Section 60 of the International Protection Act 2015. The Irish licence will allow you to drive a car (only) in Ireland for up to one year. A Ukraine licence is not valid to drive in Ireland. See also the information on the Road Safety Authority website: FAQs for Driving a Car in Ireland- A guide for Ukrainian drivers dated 28 April 2022
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.