EU Commission Updates FAQs on FDI Screening Regulation (EU) 2019/452
On 14 May 2025, the European Commission published an updated
version of its Frequently Asked Questions (FAQs) concerning the
implementation of the EU Framework for the Screening of Foreign
Direct Investments (FDIs), including guidance on its intersection
with the EU's restrictive measures (sanctions).
This update impacts for all stakeholders engaged in cross-border
investments, particularly those involving third-country investors,
including from Russia and Belarus.
Key Updates:
- The Commission has revised its FAQs on the implementation of Regulation (EU) 2019/452, which establishes a unified EU framework for screening FDIs that may affect security or public order in the Union. It clarifies the scope, process and key risk indicators for Member States conducting FDI reviews.
- The FAQs reiterate the guidance first issued in April 2022 regarding systematic screening of investments originating from Russia and Belarus. This includes investments involving entities directly or indirectly controlled by the Russian or Belarusian government, those subject to sanctions, or those influenced by geopolitical objectives that may threaten EU security or public order.
- The updated document explicitly outlines how FDI screening mechanisms complement EU sanctions. Notably, investments may be subject to scrutiny even when the investor is not individually sanctioned, if there are broader risks tied to state influence or geopolitical context.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
