Overview
Reporting obligations that apply in EU member states are set out in the EU regulations for each sanctions regimes. Reports are to the national competent authorities of individual member states. EU sanctions regulations explain who must report sanctions information and what information should be shared.
There is an EU Whistleblower Tool to report suspected sanctions violations to the European Commission. The Commission assesses these reports and may pass them on to the relevant national competent authority.
Member States are responsible for enforcing reporting requirements. Some Member States supplement EU reporting requirements with their own reporting requirements. These are contained in national legislation. For more information on this legislation, see our ‘sanctioning states’ pages.
General
EU sanctions regimes which impose targeted financial sanctions have the same basic reporting requirement. The regulations which set out each EU regime contain an obligation for ‘natural and legal persons, entities and bodies’ to:
“supply immediately any information which would facilitate compliance with [the sanctions regulation], such as information on accounts and amounts frozen, to the competent authority of the Member State.”
The above obligation is present in all EU sanctions regimes which include targeted financial sanctions. The obligation to report information that facilitates compliance (see above) applies “‘notwithstanding’ or ‘without prejudice to’ ‘the applicable rules concerning reporting, confidentiality and professional secrecy.’” – this wording appears in all EU sanctions regulations. EU sanctions on Russia and Belarus say that the obligation to report information to facilitate compliance applies where it is ‘consistent’ with professional confidentiality between lawyers and their clients (see below). The extent to which lawyer-client confidentiality overrides the reporting obligation depends on the national law of the relevant EU Member State.
Some EU regimes contain additional reporting obligations which require more detailed information or oblige actors in certain sectors to report particular transactions / activities.
The EU’s Russia sanctions regime has the most extensive reporting requirements, set out in Regulation (EU) 269/2014 and Regulation (EU) 833/2014. Sanctions on Belarus, North Korea, and those accused of terrorism also contain additional reporting requirements set out in the relevant sanctions regulations (see below).
All other EU regimes contain just the obligation to report information which would ‘facilitate compliance’ as described above.
Russia
The EU’s Russia sanctions regime is split across 6 broad categories, details of which are on our Russia sanctions page. These categories have different reporting obligations:
Targeted sanctions
Targeted sanctions on Russia are in Regulation (EU) 269/2014, which provides that:
- Those reporting assets or funds held by designated persons must report information which facilitates compliance (see above). These reports must include detailed information which is set out at Article 8(1a).
- Those designated under the Regulation must report any funds or economic resources they own or control within the EU within 6 weeks.
- These reporting obligations apply ‘consistent with respect for the confidentiality of communications between lawyers and their clients’.
Sectoral sanctions
EU sectoral sanctions on Russia are in Regulation (EU) 833/2014, which states that:
- Member States are to provide for reporting requirements related to exports of dual-use technology to Russia under Article 2(3b).
- There are a series of reporting requirements for people, vessels, and companies involved in transporting Russian crude oil under Articles 3eb, 3m, 3n and 3r. The EU’s guidance on the oil reporting obligation has more details.
- Companies and individuals which hold assets and reserves of the Central Bank of Russia must report every 3 months under Article 5a. Any sudden loss of assets engages an immediate reporting obligation.
- Credit institutions must provide updates on deposits exceeding EUR 100,000 with links to Russia every 12 months under Article 5g.
- EU legal entities which are owned for more than 40% by Russian companies or nationals must report transfers of more than EUR 100,000 out of the EU under Article 5r. The EU has published guidance on this reporting obligation and a form for reporting transactions is here.
Hybrid Threats and Human Rights
The Russia Hybrid Threats sanctions regime is in Regulation (EU) 2024/2642. In addition to the requirement to report any information which facilitates compliance with the sanctions regime (see above), designated persons must report any economic resources they own or control within the EU within 6 weeks of being listed. Under Directive (EU) 2024/1226, which aims to harmonise criminal penalties for sanctions offences in EU Member States, Member States must ensure that circumvention by failing to provide information to competent authorities is punishable by a maximum term of 1 year in prison where the value of the assets or funds in question is more than EUR 100,000. Circumvention of sanctions is now a criminal offence in many EU Member States.
The Russia human rights sanctions regime set out in Regulation (EU) 2024/1485 has the same reporting provisions as the Russia Hybrid Threats sanctions regime.
Ukrainian regions
The EU Crimea and Sevastopol sanctions regime set out in Regulation (EU) 692/2014 does not contain the general reporting obligation. Article 3e of Regulation (EU) 682/2014 sets out notification requirements for exports undertaken in an emergency.
The EU’s Donetsk and Luhansk sanctions regime set out in Regulation (EU) 2022/263 also does not contain the general reporting obligation. It has an identical notification requirement for exporters operating in emergency circumstances at Article 7.
These sanctions regimes do not have general reporting requirements because they do not impose targeted financial sanctions.
Belarus
The EU’s Belarus sanctions regime is in Regulation (EC) 765/2006. It includes the requirement to report ‘any information that would facilitate compliance’. Listed people and entities must report any economic resources they own or control within the EU within 6 weeks from their date of listing. Under Directive (EU) 2024/1226, which aims to harmonise criminal penalties for sanctions offences in EU Member States, Member States must ensure that circumvention by failing to provide information to competent authorities is punishable by a maximum term of 1 year in prison where the value of the assets or funds in question is more than EUR 100,000. Circumvention is now a criminal offence in many EU Member States.
The Belarus sanctions regime reporting requirements apply ‘consistent with respect for the confidentiality of communications between lawyers and their clients’ (Article 8j of Regulation (EU) 765/2006).
North Korea / DPRK
The EU’s North Korea sanctions regime is in Regulation (EU) 2017/1509. It includes the requirement to report any information which facilitates compliance with the sanctions regime. In addition, financial institutions must report suspicious transactions to the relevant national competent authority for analysing suspicious transactions under Article 23. See our North Korea sanctions regime page for details.
Terrorism
The EU has 2 terrorism sanctions regimes. More information on these sanctions regimes is on our Terrorism sanctions page. These sanctions regimes contain the general reporting requirement and an obligation for natural and legal persons to report information related to circumvention of any of the Regulation’s provisions to the relevant national competent authorities.
Council Regulation (EU) 2016/1686
Council Regulation (EC) No 2580/2001
Other EU sanctions regimes
All other EU sanctions regimes (the full list is available on our EU Legislation page) have the following reporting requirement:
‘Without prejudice to the applicable rules concerning reporting, confidentiality and professional secrecy, natural and legal persons, entities and bodies must supply immediately any information which would facilitate compliance with [the sanctions regulation], such as information on accounts and amounts frozen, to the competent authority of the Member State.”