The DNB provides information regarding various reporting obligations for deposits related to sanctions against Russia and Belarus. Banks are expected to take specific actions based on these requirements.
Here are the key points:
– Reporting Obligations for Deposits:
Banks must comply with reporting obligations under Article 5 octies of Regulation 833/2014 (Russia) and Article 1 septvicies of Regulation 765/2006 (Belarus). The reporting obligations apply to deposits exceeding 100,000 EUR held by Russian or Belarusian nationals, individuals residing in Russia or Belarus, or legal entities established in Russia or Belarus. The first reporting deadline is by 27 May 2022, and subsequently every 12 months thereafter
– Reporting of Deposits Owned by Russian Nationals:
An additional provision (article 5 octies of Regulation 833/2014) has been added in the December 2022 sanctions package.
This provision requires credit institutions to provide a list of deposits exceeding 100,000 EUR owned by legal entities established outside the Union, with ownership rights of more than 50 % held by Russian nationals or individuals residing in Russia.
Updated information about such deposits must be provided every 12 months, with the deadline set for 27 May 2023.
– Reporting Process:
The DNB served as the reporting point for the previous notifications in 2022, as well as for current reporting obligations, but it will not oversee compliance. Banks are required to report the specified deposits to DNB and must submit the information by 18 July.
Reporting should be done using the formats provided by the European Commission through the EBA templates
– Reporting via Mijn DNB Platform:
A reporting obligation will be established in Mijn DNB. Banks can provide the required information through it based on this reporting obligation.
If there are no deposits to report, institutions should still fill in the usual identification (1 – Metadata) but can leave the other template (2 – Deposits) empty.
– Contacts for Technical and Regulatory Queries:
Technical questions regarding reporting via Mijn DNB can be directed to the designated contact person at ECTB (DNB).
Questions about sanctions regulations and reporting obligations can be directed to the Ministry of Finance via sancties@minfin.nl.