The French authorities (French Treasury – Direction Générale du Trésor) have provided an important update for operators in France regarding the renewal of licenses for the provision of intragroup services and software to Russia.
Under Article 5n of Regulation (EU) 833/2014 (“EU Russia Sanctions Regulation”), the supply of certain services and software to persons established in Russia is prohibited. However, until 30 September 2024, the supply of these services and software to Russian entities owned or controlled by parent companies in the European Union, the European Economic Area, Switzerland, and partner countries was exempt from this prohibition. This changed on 1 October 2024, when such supplies began to require authorisation granted by national competent authorities (“5n authorisation”).
In France, all authorisations delivered by the French Treasury are set to expire on 30 September 2025. In a recent communication sent to holders of 5n authorisations, the French Treasury has informed companies that the renewal of current authorisations must be submitted before the end of this month, 30 April 2025.
This deadline, which is five months before all authorisations expire, indicates that the French Treasury will likely take more time to review the applications and may pose additional questions regarding the presence of EU businesses in Russia. Applicants should therefore exercise caution and diligence when applying for a renewal of their authorisation.
