National Competent Authorities
The Central Bank of Ireland is responsible for the administration, supervision, and enforcement of sanctions. The Department of Enterprise, Trade and Employment is responsible for implementing sanctions. The Department of Foreign Affairs is responsible for liaising with EU and UN partners regarding sanctions and is in charge of licensing applications.
Legislation
Ireland does not have autonomous sanctions legislation. EU sanctions regulations have direct effect in Ireland.
S.I. No. 77/2024 provides criminal penalties for breaching EU sanctions.
Sanctions Lists
Ireland does not implement additional sanctions at national level and does not have an autonomous sanctions list.
Guidance
A number of documents providing general guidance on the implementation of EU sanctions are available on the websites of the National Competent Authorities and other Irish governmental agencies:
Central Bank of Ireland
Central Bank of Ireland – Introduction to Financial Sanctions
Central Bank of Ireland – EU restrictive measures relating to actions in Ukraine
Central Bank of Ireland – Financial Sanctions: FAQs
Central Bank of Ireland – Financial Sanctions Updates 2024
Department of Enterprise, Trade and Employment
Department of Foreign Affairs
Department of Foreign Affairs – Information on sanctions in respect of the situation in Ukraine
Department of Foreign Affairs – Restrictive Measures (Sanctions)
Department of Foreign Affairs – UN Sanctions
Department of Transport
Department of Transport – EU sanctions in response to the situation in Ukraine
Office of the Revenue Commissioners
Office of the Revenue Commissioners – Manual on EU sanctions in response to situation in Ukraine
Licensing
The Central Bank of Ireland is responsible for assessing derogation applications in respect of financial sanctions prohibitions. Further information is available on the Central Bank of Ireland’s webpage on derogations.
The Department of Enterprise, Trade and Employment is responsible for managing controls on exports of dual-use items, military items and items destined for countries to which trade sanctions apply. Further information is available on the Department of Enterprise, Trade and Employment’s webpage on export licences.
Enforcement
S.I. No. 77/2024 – European Union (Restrictive Measures concerning Ukraine) (No.3) Regulations 2024 provides that contravention of EU sanctions on Russia or contravention of an authorisation (licence) shall be liable:
(a) on summary conviction to a class A fine or imprisonment for a term not exceeding 12 months or both or;
(b) on conviction on indictment a fine not exceeding €500,000 or to imprisonment for a term not exceeding 3 years or both.
Other statutory instruments provide for the same penalties for other sanctions regimes.
Reporting
The Central Bank of Ireland’s Sanctions Reporting webpage contains information on financial sanctions reporting.
Central Bank of Ireland – Sanctions Reporting
Central Bank of Russia reporting template
Self-Declaration Reporting Form
Article 8(1)(a) second indent – prior movements reporting form
Export controls
Legislation
Guidance
Export Licensing and Control: Information for Exporters
Department of Enterprise, Trade and Employment – Introduction to Trade Sanctions
About the Export Licensing Unit
Union General Export Authorisations
Judgments
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In The Matter of GTLK Europe DAC [In Liquidation] -v- Companies Act 2014
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GTLK Europe DAC v Companies Act 2014 [2023] IEHC 674
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GTLK Europe DAC v Companies Act 2014 [2023] IEHC 486
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Pola Logistics Limited v GTLK Europe DAC & Ors [2022] IEHC 501