On 15 June 2022, the Cyprus Securities and Exchange Commission (CySEC) published Circular 517 providing a detailed analysis on the amendments and additions made to Council Regulation (EU) 2022/879 of 3 June 2022, amending Regulation (EU) No 833/2014 concerning the Article 5m (amended), Article 3m (new) and Article 5n (new).

1. Article 5m - Services to trusts and other similar legal arrangements
2. Article 3m (new) - Crude oil and related products ban
3. Article 5n (new) - Accounting, consultancy, and other services

Our recent blog post on the sixth EU package of restrictive measures, can be found here, providing a thorough explanation to the above Articles.

All Regulated Entities that are affected by the said sanctions are expected to inform CySEC by Tuesday, 21 June 2022, regarding the appropriate actions/measures taken or intended to be taken by the Regulated Entity for compliance with Articles 5m, 5n and 3m, if applicable.

CySEC prompts the Regulated Entities of their obligation to report to CySEC the existence of business relationships with persons or entities subject to the EU Council's Restrictive Measures against Russia due to its military aggression against Ukraine, constitutes a continuous obligation and requires compliance for both existing EU Council's Restrictive Measures, and those which may be imposed in the future against Russia for its military aggression against Ukraine.

CySEC’s Circular 517 can be found here.