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EU says don't help Russians in Russia and Russian trusts or similar legal arrangements


As part of the EU's efforts to prevent circumvention of the new measures targeting Russia, it will now be prohibited to

  1. Register, provide a registered office, business or administrative address as well as management services to a trust or any similar legal arrangement having as a trustor or a beneficiary:
    • Russian nationals or natural persons residing in Russia;
    • Legal persons, entities or bodies established in Russia;
    • Legal persons, entities or bodies whose proprietary rights are directly or indirectly owned for more than 50 % by a natural or legal person, entity or body referred to in points (a) or (b);
    • Legal persons, entities or bodies controlled by a natural or legal person, entity or body referred to in points (a), (b) or (c);
    • A natural or legal person, entity or body acting on behalf or at the direction of a natural or legal person, entity or body referred to in points (a), (b), (c) or (d).

Furthermore, as of 10 May 2022,

  1. It will be prohibited to act as, or arrange for another person to act as, a trustee, nominee shareholder, director, secretary or a similar position, for a trust or similar legal arrangement as referred to above.
  2. Operations that are strictly necessary for the termination by 10 May 2022 of contracts which are not compliant with the prohibitions set out above concluded before 9 April 2022 or ancillary contracts necessary for the execution of such contracts are exempted from the prohibitions referenced above.

The new regulations also include the following new financial and business restrictions:

  1. The previous prohibition on the sale of euro denominated transferable securities issued after 12 April 2022 or units in collective investment undertakings providing exposure to such securities, to any Russian national or natural person residing in Russia or any legal person, entity or body established in Russia, now extends to
    1. transferable securities denominated in any official currency of a Member State issued after 12 April 2022.
    2. A prohibition to provide direct or indirect support, including financing and financial assistance or any other benefit under a Union, Euratom or Member State national programme and contracts within the meaning of Regulation (EU, Euratom) 2018/1046, to
      • Any legal person, entity or body established in Russia with over 50 % public ownership or public control. This prohibition is subject to certain exceptions.



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