In view of the extraordinary circumstances created due to the situation in Ukraine, a decision has been made for the set-up of a working group (the “Group”) responsible for the coordination and procedures for the implementation of the economic sanctions decided at an EU institutional level, providing guidelines to market participants in need of guidance. The Group will address questions that need clarification, and generally will manage the emergency by exchanging views, disseminating relevant information and, where possible, clarifying questions from market participants for the correct interpretation and application of relevant EU Regulations, mediating, inter alia, the provision of clarifications by the European Commission.
The Group consists of representatives of the Legal Office of the Republic, the Central Bank of Cyprus, the Ministry of Foreign Affairs, the Ministry of Finance, the Ministry of Interior, the Ministry of Energy, Commerce and Industry, the Cyprus Securities and Exchange Committee (CySEC) and the Insurance Audit Service.
The existing procedures and mechanisms for the examination of requests by the Financial Sanctions Advisory Committee – Συμβουλευτική Επιτροπή Οικονομικών Κυρώσεων (ΣΕΟΚ) and the Sanctions Enforcement Unit – Μονάδα Εφαρμογής Κυρώσεων (MEK) are still in force and mainly concern the following:
The Financial Sanctions Advisory Committee (ΣΕΟΚ) examines requests from credit institutions (for their clients, natural or legal persons) which are included in Regulation (EU) 269/2014 of the EU Council (the “Regulation”) as well as the recent Regulations that amend it, for exemption and release of certain frozen resources or funds, conditionally, if this is considered necessary for certain reasons, including possible necessity to meet the basic needs of the natural or legal persons, entities or bodies listed in the Regulation and their dependent family members, payment of reasonable professional remuneration or to cover the costs associated with the provision of legal services; payment of fees or charges for services relating to the ordinary maintenance or safekeeping of frozen funds or financial resources.
The Sanctions Enforcement Unit (MEK) examines requests submitted by interested parties (e.g. Cypriot citizens, Cypriot companies, law firms, financial institutions) regarding the authorizations / approvals provided by the relevant Resolutions of the UN and EU Regulations and are related to financial issues.
The Working Group will issue Q&A to assist and guide stakeholders and the public as well as publish useful documents and links regarding restrictive measures.
For more information please speak with any member of our dedicated Financial Services and Regulation team or your usual contact at Elias Neocleous & Co LLC.