EU Final Guidance on Implementation of EU And National Sanctions

The European Banking Authority has finalized two sets of guidelines setting common standards on the governance arrangements and the policies, procedures, and controls that financial institutions should have in place to be able to comply with EU and national restrictive measures. Restrictive measures applicable to financial institutions comprise targeted financial sanctions and sectoral measures, e.g., economic and financial measures. Both sets of guidelines will apply from December 30, 2025.

The first set of guidelines is addressed to all institutions within the EBA's supervisory remit, i.e., those regulated and supervised under the Capital Requirements Directive, the Payment Services Directive, and the Electronic Money Directive. These guidelines set out the governance and risk management systems that financial institutions should implement to address the risk of potentially breaching or evading restrictive measures.

The second set of guidelines is specific to restrictive measures under the Wire and Cryptoasset Transfer Regulation. The guidelines specify what payment service providers and crypto-asset service providers should do to be able to comply with restrictive measures when performing transfers of funds or crypto-assets.

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