Sanctions Lists

• EU Sanctions Policy - see this page for information about EU Sanctions and a link to the Consolidated list of EU Financial Sanctions.

• Consolidated United Nations Security Council Sanctions List - see this page for information about UNSC Sanctions and a link to the Consolidated UNSC Sanctions List.

Sanctions are binding on all natural and legal persons. The competent authorities for sanctions in Ireland are the Central Bank, the Department of Jobs, Enterprise and Innovation and the Department of Foreign Affairs. These organisations constantly update their websites with information about sanctions as they are enacted together with information about how everyone can comply. The key websites are below:

• Central Bank website
• Department of Enterprise, Trade & Employment
• Department of Foreign Affairs    

Given recent events in Ukraine, the Department of Foreign Affairs restrictive measures web page contains links to the information notices from competent authorities: 

• Department of Foreign Affairs information note on the first EU sanctions package in respect of the situation in Ukraine dated 24 February 2022.
• Department of Enterprise, Trade and Employment notice on EU sanctions in response to the situation in Ukraine (10 March 2022).
• Central Bank of Ireland notice on changes to the Russia/Ukraine Regulations as of 23 February 2022.

Sanctions have been a key tool in the fight against terrorism for many years and the Law Society has raised awareness among solicitors about sanctions across all of its anti-money laundering and counter-terrorist financing (AML/CTF) outreach initiatives comprising guidance, resources and training. Examples of the ways in which a solicitor’s AML compliance will consider sanctions include the following:

• When completing money laundering risk assessments (on both a business and individual client level), solicitors must consider statutory low and high risk factors including customer and country/geographical risk which includes consideration of sanctions

• A key AML tool for solicitors is the Society’s sample adaptable Business Risk Assessment form which ensures firms consider whether jurisdictions in which their clients (or the beneficial owners of their clients) are based (or from which they operate their businesses) may be the subject of sanctions

• The Society’s AML guidance further recommends that, to effectively manage the money laundering risks firms face, solicitors should be aware of which jurisdictions are on the European Commission list and information about financial sanctions provided by the Central Bank.  In addition, firms should have a process for checking clients against the sanctions lists where they have a connection with a jurisdiction which is on the sanctions list

High Risk Jurisdictions lists

Visit the sites below for more information:

• FATF high risk and non-cooperative jurisdictions list
• Transparency International corruption perceptions index
• Transparency International corruption by territory page
• CIA world fact book