On 1 March 2022, Luxembourg’s Commission de Surveillance du Secteur Financier (CSSF) published a circular letter, drawing the attention of the professionals of the financial sector subject to its supervision to the restrictive measures decided by the European Union in response to the current situation in Ukraine and in particular to those that were adopted and entered into force on 23, 25, and 28 February 2022, as well as to those which will be taken by the EU in the future.

The CSSF advises that these regulations are binding in their entirety and directly applicable in national law and that professionals are required to comply, while putting in place the necessary controls and measures. The professionals must also assess whether, in addition to the restrictive measures directly applicable in Luxembourg, other financial restrictive measures of third countries must be implemented by professionals according to the international nature of their activities.

The CSSF further stressed that following the entry into force of the Law of 19 December 2020 on the implementation of restrictive measures in financial matters, it is expected that the persons and entities subject to its supervision apply these restrictive measures immediately.

CSSF’s circular letter can be found here.

The Law of 19 December 2020 can be found here.

Our recent blog post with the updated table on EU sanctions on Russia – Ukraine – Belarus, can be found here.