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IRELAND’S OFAC SANCTIONS LIST: WHAT YOU NEED TO KNOW

In a bid to curb terrorist financing and proliferation of weapons of mass destruction, Ireland has implemented restrictive measures, commonly referred to as financial sanctions. The Central Bank of Ireland provides frequent updates on these sanctions, which are contained in lists published by the European Union (EU) and the United Nations (UN).

EU Financial Sanctions

The EU implements financial sanctions autonomously or through UN resolutions, publishing regulations that are binding on all member states. These sanctions aim to prevent terrorist financing and proliferation of weapons of mass destruction.

Targeted Financial Sanctions: A Specific Type of Sanction

One type of financial sanction is the Targeted Financial Sanction, which has a stated objective, including the prevention of terrorist financing. These sanctions can originate from the supranational level (EU) or international level (UN). The EU gives legal effect to UN designations through its regulations.

There is a legal obligation to comply with EU regulations relating to financial sanctions as soon as they are adopted. Once a person, entity, or body has been sanctioned under EU Financial Sanctions, there is a legal obligation not to transfer funds or make funds or economic resources available directly or indirectly to that individual or entity.

Penalties for Breach of Financial Sanctions

The penalties for breaching financial sanctions in Ireland are contained in Irish statutory instruments. A list of these instruments can be found on the Irish Statute Book website.

Guidance for Credit and Financial Institutions (Firms)

Firms must ensure they comply with financial sanctions, including ongoing monitoring of transactions. This includes monitoring both the EU Financial Sanctions list and the UN Sanctions Committees list relating to terrorism and proliferation of weapons of mass destruction.

What to Do if a Match or ‘Hit’ Occurs

If a match or “hit” occurs against a sanctioned individual, entity, or body, firms must immediately freeze accounts and/or stop transactions and report the “hit” to the Central Bank by email using the Sanctions Return Form. Further information on sanctions reporting can be found on the Central Bank’s dedicated Sanctions Reporting webpage.

EU Sanctions Whistleblower Tool

If you are aware of possible violations of any EU sanctions, you can bring this to the attention of the European Commission by voluntarily providing information. This includes facts concerning sanctions violations, their circumstances, and the individuals, companies, and third countries involved.

Competent Authorities for Financial Sanctions

The Central Bank is responsible for financial regulation in Ireland and is one of three competent authorities for EU sanctions. The other Irish competent authorities are the Department of Enterprise, Trade and Employment and the Department of Foreign Affairs.

Further Information

Further information on EU restrictive measures (sanctions) can be found on the European Commission’s website, while further information on UN sanctions can be obtained from the United Nations Security Council’s website. Contact the Central Bank’s financial sanctions unit at [email address] for more information.