Restrictive measures on Trusts against the Russians

The Council of the European Union decided to impose additional restrictive measures against Russia and Belarus EUR-Lex – 32022R0576 – EN – EUR-Lex (Europa.eu)

The new sanctions cover, inter alia, restrictive measures for trusts. 

Pursuant to the relevant Article, it is prohibited to register, provide a registered office, business, or administrative address, as well as management and administrative services, in new trusts or in any similar new legal form or arrangement that has as trustees or beneficiaries:

(a) Russian nationals or natural persons residing in Russia;

(b) legal persons, entities, or bodies incorporated in Russia;

(c) legal persons, entities, or bodies the ownership of which is directly or indirectly owned by more than 50% of a natural or legal person, entity, or body referred to in points (a) or (b);

(d) legal persons, entities, or bodies controlled by a natural or legal person, entity, or body referred to in points (a), (b), or (c);

(e) a natural or legal person, entity, or body acting on behalf of or on behalf of a natural or legal person, entity, or body referred to in points (a), (b), (c), or (d).

It is noted that these prohibitions do not apply to companies but only to trusts. 

As of 10 May 2022, it is prohibited to act or arrange for another person to act as a trustee, authorized / nominee shareholder, director, secretary, or similar, for a new trust or a new similar arrangement.

Such prohibitions shall not apply where the trustee or beneficiary is a national of a Member State or a natural person holding a temporary or permanent residence permit in a Member State.

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