New EBA Guidelines On Restrictive Measures Key Take-Aways

On 14 November 2024, the European Banking Authority ("EBA") released two sets of guidelines relating to the handling of European and national sanctions by financial institutions and payment service providers. This note provides an overview of key take-aways from these new guidelines. While certain financial institutions are now receiving some regulatory guidance, other companies are facing the challenge of having to establish effective sanctions compliance programs for the very first time. Though not directly applicable, the EBA guidelines might provide some ideas that can be put into practice.

Why the EBA guidelines on sanctions?

Under the amended European Fund Transfer Regulation ("FTR" – Regulation (EU) 2023/1113) EBA was mandated to issue guidelines to assist payment service providers ("PSPs") and crypto-asset service providers ("CASPs") put in place internal policies, procedures and controls that will ensure implementation of both European and national