At the beginning of 2024, the EU Council amended Regulation No 833/2014 by adding Article 5r, introducing a mandatory reporting requirement for payments made by EU-registered entities with significant ties to Russia:
EUR-Lex – 02014R0833-20240224
From May 1, 2024, legal entities, organizations, and bodies registered in the EU that are directly or indirectly owned more than 40% by: (a) legal entities registered in Russia;
(b) Russian citizens*;
(c) individuals residing in Russia,
*including Russian citizens with additional citizenships and those residing permanently outside of Russia,
must report any fund transfers outside the EU if the total transferred in a quarter exceeds €100,000.
This obligation covers both direct and indirect transfers, including those through multiple intermediaries within the EU. It also applies to Russian citizens with dual citizenship, even if they hold EU citizenship.
The report must be submitted to the competent authority in the member state where the legal entities are registered (in Estonia, this is the RAB).
Although this obligation becomes effective on May 1, 2024, the first report should cover the period from January 1 to March 31. Subsequent reports must be filed within two weeks after each quarter ends, meaning the second quarter report is due by July 15.
A similar requirement applies to credit and financial institutions, which must report information on fund transfers outside the Union exceeding €100,000 per quarter.
Further information on Article 5r can be found in the FAQ published by the European Commission:
FAQs on sanctions against Russia and Belarus.