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ARTICLE · 09 MAY 2022

EU Sanctions Against Russia And Potential Implications For Irish Pension Schemes

Arthur Cox
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Does your Irish occupational pension scheme have Russian pensioners, Russian deferred members or Russian participating employers?

GlobalInternational Law
Philip Smith
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Sarah McCague
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Does your Irish occupational pension scheme have Russian pensioners, Russian deferred members or Russian participating employers?

If so and you are an Irish pension scheme trustee then you have a potential issue to manage from 10 May 2022.

The issue

The EU has adopted a new round of sanctions against Russia which take effect on 10 May 2022.  EU Council Regulation 2022/576 of 8 April 2022  amends Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (the "Regulation"). From 10 May 2022, the new sanctions prohibit EU persons from acting as a trustee for a Russian trust or any similar legal arrangement. The Regulation prohibits the administration of a trust or any similar legal arrangement having as a settlor or a beneficiary, amongst others:

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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