EU publishes FAQs concerning sanctions against Russia and new reporting obligations

According to the FAQs, Article 5r establishes new reporting requirements intended to provide national competent authorities (“NCAs”) with information on the flow of funds out of the European Union related to Russian-owned entities as opposed to entities that are partly Russian-owned and are legitimately operating in the European Union. The reports are also intended to enable NCAs to better assess whether certain types of transfers pose a risk of violating Russia-related sanctions and to help determine the sources of Russia’s revenue…