On 27 October 2022, the European Commission updated its frequently asked questions (FAQs) on a number of key areas of EU Russia sanctions.

The updates affect the following matters:

• Asset freeze and prohibition to provide funds or economic resources – can be found here
• Central securities depositories – can be found here
• Provision of services – can be found here
• The Consolidated version of the updated FAQs on the Council Regulation No 833/2014 and Council Regulation No 269/2014 -here

Importantly, the updates provide guidance on:

• The exercise of voting rights by persons designated as being subject to an asset freeze
• The use of conversion schemes of depositary receipts into the underlying shares of Russian issuers
• The types of services which are caught by the restrictions on providing services to the Russian Government or legal persons, entities or bodies established in Russia, as well as the scope of the available exemptions

The official EU Commission’s page on the FAQs for all the Russia sanctions and restrictive measures imposed can be found here.