This guidance is for members in the Republic of Ireland. For members in Northern Ireland and Great Britain, please read the UK guidance article.
The developments in Ukraine have led to an EU package of sanctions. The Central Bank of Ireland has a web page linking to the list of sanctions and information on sanctions in general.
Statutory Instruments enacting the legislation in Ireland are available on the Irish Statute Book. More information specific to the situation in Ukraine is available from the Central Bank of Ireland.
Domestic guidance on the implementation of sanctions is also available from the Department of Foreign Affairs (DFA). Additional sanctions are likely to be added at short notice, the web resources should be monitored closely for any updates.
The Department of Finance, Anti-Money Laundering/Terrorist Financing Unit, have said that they may request information from designated persons at short notice. The Dept. have also said that if your organisation, or any organisation you represent, has relevant information on the implementation of financial sanctions in Ireland, you are invited to contact firstname.lastname@example.org.
ACCA expects Irish firms to have established systems and controls to counter the risk that they might be used to further economic crime, including compliance with financial sanctions obligations.
Our expectations of firms’ systems and controls in relation to compliance with financial sanctions are set out in our technical release, Anti-Money Laundering Guidance, Republic of Ireland (PDF, 1.2MB), section 5.3.24 et. Seq. Note that updated Anti-Money Laundering Guidance, Republic of Ireland will issue shortly, but the guidance in respect of this specific issue will not materially change in the update.
Firms should follow their risk-based approach on how they screen current and new clients against the Financial Sanction Lists to meet these new sanctions measures. Note that the format used for the sanctions list used in the UK is more easily electronically searched and is likely to be the same as the EU list, so you may find it useful to check The UK Sanctions List first.
Where clients give rise to concerns about sanctions evasion or money laundering, you should also consider your obligations to report to the Financial intelligence Unit and to Revenue.
For further details on financial sanctions, you should contact the Central Bank of Ireland or, for trade and export sanctions, the Department of Enterprise, Trade and Employment (DETE).
If you require a licence to permit any activity that would otherwise be prohibited by sanctions regulations, you must contact the relevant department.
Applications must be made in advance of any business agreement or transaction taking place.
Firms should be aware that these sanctions are subject to change and should maintain up-to-date screening processes.
Guidance and supporting tools to help with the risk assessment of clients are available on ACCA Ireland technical pages.