Ireland

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 Enterprise, Trade and Employment – EU trade sanctions in response to situation in Ukraine

Department of Enterprise, Trade and Employment – Guidance Note: EU trade sanctions in response to Russia’s aggression against Ukraine

Department of Enterprise, Trade and Employment: Export Licensing and Control: Information for Exporters

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.

Central Bank of Ireland – Derogations

Sanctions Derogation Application Form

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

Sanctions Return Form

Self-Declaration Reporting Form

Article 8(1)(a) second indent – prior movements reporting form

Export controls

Legislation

Control of Exports Act, 2008

Guidance

Export Licensing and Control: Information for Exporters

Export Licences FAQs

Department of Enterprise, Trade and Employment – Introduction to Trade Sanctions

Export licences

About the Export Licensing Unit

Union General Export Authorisations

Exporter notifications

Export controls – publications

Controlled products

Procedures for applying for an export licence

Judgments

• 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

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