EU Adds 2 Sanctions FAQs on Donetsk, Kherson, Luhansk, Zaporizhzhia
The European Commission added to its sanctions FAQs for the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts on April 18.
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One of the FAQs asks how operators should assess which areas in the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts are subject to restrictions. The commission said the sanctions cover "all areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts of Ukraine that are not under the control of the authorities of Ukraine," adding that a "dynamic assessment of this control could be necessary." As of April 18, the cities of Zaporizhzhia and Kherson are under Ukrainian control, the commission said.
A second FAQ asked if banks can process financial transactions in connection with trade done in the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts and, if so, under what conditions. The commission said that processing payments into bank accounts in the non-government-controlled areas isn't restricted and that there "are no restrictions to financial transactions processed by EU credit institutions in support of trade in the government-controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts."
The commission said that to assess whether the financial transaction is being processed in an area controlled by the Ukrainian government or not, "EU credit institutions can take into account the relevant indicators, including by relying on Ukrainian banks active in the area whose reliability is proven by past experience or by liaising with the Ukrainian authorities, e.g. the National Bank of Ukraine, to obtain updated information."