• Transaction ban: A full prohibition on transactions with legal persons, entities or bodies listed in Annex XIV (previously only a SWIFT ban), including any Russian entities owned by more than 50 per cent of these listed entities. The list is expansive and includes 45 Russian banks.
• Licensing grounds: Certain transactions may be authorised, such as:
  • Divestment or wind-down of business activities in Russia, subject to approval by competent authorities.
  • Specific transactions with Bank Zenit for the necessary execution of pre-2025 contracts or for the payment of essential goods.
• Exemptions: Certain transactions are exempt from the prohibition, such as:
  • Activities necessary for diplomatic and consular functions.
  • Transactions by EU nationals residing in Russia before 24 February 2022.

CySEC urges all regulated entities, including CIFs, AIFMs, UCITS managers and CASPs, to review and update their compliance measures, emphasising that the scope of the Article 5h prohibition was changed from a prohibition to provide specialised financial messaging services (SWIFT) to a complete transaction ban.

Entities are also encouraged by CySEC to consult the EU’s consolidated FAQs for detailed guidance on Article 5h and related provisions.

These measures reflect the EU’s commitment to enforcing stricter sanctions and ensuring alignment across member states. Regulated entities must act promptly to harmonise their procedures with the updated requirements.

CySEC’s Circular C728 can be accessed here and Article 5h of Council Regulation (EU) 833/2014 here

EU’s consolidated FAQs can be found here