Obligation of Russian-affiliated businesses and banks operating in Finland to report on transfers of over EUR 100,000 enters into force
Russian-affiliated businesses and banks operating in Finland have an obligation to regularly report to the Ministry for Foreign Affairs on transfers of funds exceeding EUR 100,000 from Finland to third countries. The first reports are due by 15 May 2024. A standardised reporting template must be used for submitting the reports.
The 12th package of sanctions against Russia adopted in December 2023 imposed a new obligation to report on transfers of funds out of the European Union. The reporting obligation applies to:
- Legal persons, entities and bodies established in the European Union whose proprietary rights are directly or indirectly owned for more than 40 per cent by a) a legal person, entity or body established in Russia; b) a Russian national; or c) a natural person residing in Russia; and
- Credit and financial institutions
Legal persons, entities and bodies established in the European Union, as referred to above, must report to the Ministry for Foreign Affairs any transfer of funds exceeding EUR 100,000 to third countries. The first reporting obligation applied to the period 1 January 2024 – 31 March 2024. Data for the first quarter is due to be submitted by 15 May 2024. In future, reports must be submitted within two weeks of the end of each quarter. The data for the next reporting period 1 April 2024 – 30 June 2024 is due to be submitted to the Ministry for Foreign Affairs by 15 July 2024.
Credit and financial institutions must report to the Ministry for Foreign Affairs information on all transfers of funds out of the Union of a cumulative amount, for the period 1 January 2024 – 30 June 2024, exceeding EUR 100,000 that they initiated, directly or indirectly, for the legal persons, entities and bodies referred to in section 1. Credit and financial institutions must submit the data for the first half of the year between 1 July 2024 and 15 July 2024, and from then on, regularly every six months. The reporting obligation also applies to banks' branches and subsidiaries located in Finland.
The reporting obligation is based on Article 5 r of Council Regulation (EU) No 833/2014(Link to another website.).
Reports are produced using the standardised reporting template provided below and sent to the Foreign Ministry’s Sanctions Team by email to pakotteet.um@gov.fi using the Ministry's secure email service https://turvaviesti.gov.fi/index.cgi/(Link to another website.) or some other secure email solution.
More information on reporting is available in section 13 (starting on page 102) of Commission consolidated FAQs(Link to another website.) and from the Sanctions Team of the Foreign Ministry’s Legal Service at pakotteet.um@gov.fi.