Some Factors for Financial Services Firms to Consider in light of the War between the Ukraine and the Russian Federation

The Commission is monitoring the situation and has been, through its 2021 thematic work on sanctions screening and other interactions, encouraging firms to prioritise their sanctions monitoring and assessment of sanctions risks. The Commission requests that all firms check whether they maintain any accounts or otherwise have any kind of relationship with the persons referred to in sanctions notices, and if firms identify that they maintain relationships with sanctioned persons, reminds firms that they must treat any funds, other assets or economic resources as frozen.  Frozen funds should be reported in accordance with the law.

All firms involved in investment in countries involved in armed conflict should also take care to ensure that investors are treated equitably, especially in terms of fair valuation and allocation of liquid and illiquid assets between investors.

Given the increasing volatility in the geopolitical landscape, the Commission is enhancing its financial stability monitoring work. We would appreciate firms’ swift cooperation with our enquiries.

Given the deteriorating international situation, all firms are requested to check they are familiar with the Commission’s Cyber Rules and Guidance, 2021, noting the need to ensure they:

• have appropriate cyber security software in place;
• implement IT systems updates in a timely manner; and
• encourage their staff to exercise caution by not clicking on or opening unfamiliar links in emails or on websites.

If firms experience any difficulties in relation to these matters, we encourage them to bring those matters to our attention through their normal supervisory contacts at the earliest opportunity.