On 31 July, we reported that the EU had issued “Stage 3” sanctions against Russia through the implementation of Council Regulation (EU) No 833/2014, in response to Russia’s actions destabilising the situation in Ukraine (please click here to view our previous post).

On 21 August, a Corrigenda to Council Regulation (EU) No 833/2014 was published in the Official Journal of the European Union, therein making the following changes to its provisions:

On page 1, recital 5:

for: ‘(5)

It is also appropriate to apply restrictions on access to the capital market for certain financial institutions, excluding Russia-based institutions with international status established by intergovernmental agreements with Russia as one of the shareholders. Other financial services such as deposit business, payment services and loans to or from the institutions covered by this Regulation, other than those referred to in Article 5, are not covered by this Regulation.’,

read: ‘(5)

It is also appropriate to apply restrictions on access to the capital market for certain financial institutions, excluding Russia-based institutions with international status established by intergovernmental agreements with Russia as one of the shareholders. Other financial services such as deposit business, payment services and loans to or from the institutions covered by this Regulation, other than those referred to in Article 5, are not covered by these restrictions.’;

on page 4, Article 4(4):

for: ‘4.

Where authorisations are requested pursuant to paragraph 2 of this Article, Article 3, and in particular paragraphs 2 and 5 thereof, shall apply mutatis mutandis.’,

read: ‘4.

Where authorisations are requested pursuant to paragraph 3 of this Article, Article 3, and in particular paragraphs 2 and 5 thereof, shall apply mutatis mutandis’.

We note that the amendment to Article4(4) addresses what was always thought to be an error due to the confusion that it caused around the application of the authorisation regime.

Please click here for the official press release.

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