Reporting obligation
Reporting of deposits in excess of EUR 100,000 by credit institutions
The restrictive measures introduced by the EU in response to the war in Ukraine include provisions that prohibit, with certain exceptions, the acceptance of deposits from Russian and Belarusian persons if the sum of the holdings exceeds EUR 100,000.
For existing deposits or balances at credit institutions as at the day of the entry into force of the two regulations, there is a reporting obligation, which is illustrated in the table below:
Content of reporting |
Legal basis |
Reporting deadline |
Reporting date |
Deposits exceeding EUR 100,000 held by Russian nationals or natural persons residing in Russia, or by legal persons, entities or bodies established in Russia |
First reporting: 27 May 2022 Each year by 27 May
|
First reporting: 26 Feb 2022 Subsequent reporting: data as at 26 Feb of the reporting year |
|
Deposits exceeding EUR 100,000 held by a legal person, entity or body established outside the EU and whose proprietary rights are directly or indirectly owned more than 50% by Russian nationals or natural persons residing in Russia |
First reporting: 27 May 2023 Each year by 27 May
|
First reporting: 17 Dec 2022 Subsequent reporting: data as at 17 Dec of the reporting year |
|
Deposits exceeding EUR 100,000 held by Russian nationals or natural persons residing in Russia who have acquired the citizenship of a Member State or residence rights in a Member State through an investor citizenship scheme or an investor residence scheme |
First reporting: 27 May 2022 Each year by 27 May
|
First reporting: 26 Feb 2022 Subsequent reporting: data as at 26 Feb of the reporting year
|
|
Deposits exceeding EUR 100,000 held by Belarusian nationals or natural persons residing in Belarus, or by legal persons, entities or bodies established in Belarus |
First reporting: 27 May 2022 Each year by 27 May
|
First reporting: 10 Mar 2022 Subsequent reporting: data as at 10 Mar of the reporting year |
|
Deposits exceeding EUR 100,000 held by Belarusian nationals or natural persons residing in Belarus who have acquired the citizenship of a Member State or residence rights in a Member State through an investor citizenship scheme or an investor residence scheme |
First reporting: 27 May 2022 Each year by 27 May
|
First reporting: 10 Mar 2022 Subsequent reporting: data as at 10 Mar of the reporting year |
Deposits of persons who hold a valid permit for residing in the EU are also reported. For ease of reporting this information, the reporting form below drawn up by the European Banking Authority (EBA) in 2022 and updated in 2023 should be used.
The reporting form is submitted to Banka Slovenije on its agreed website for secure data exchange box.bsi.si. For other correspondence, email sankcije@bsi.si.
A credit institution that is unable to submit the form for reporting on prohibited deposits by the stipulated deadline, for example because it is still gathering the information, should inform Banka Slovenije of the delay, citing the reasons and proposing a new deadline.
In connection with reporting, credit institutions should also take account of the frequently asked questions published by the European Commission, particularly those referring to deposits.
Reporting on changes in funds and economic resources two weeks before the listing of a designated person in accordance with Council Regulation (EU) No 269/2014
As of 26 April 2023 there has been a reporting obligation whereby natural and legal persons, entities and bodies should immediately submit “information held about funds and economic resources within Union territory belonging to, owned, held or controlled by natural or legal persons, entities or bodies listed in Annex I” that were subject to any move, transfer, alteration, use, access, or dealing referred to in Articles 1(e) and 1(f) of Council Regulation (EU) No 269/2014 in the two weeks before the placement of those natural and legal persons, entities and bodies on the list in Annex I, to the competent authority of the Member State where they are resident or located, within two weeks of acquiring this information.
For ease of reporting this information, the reporting form below should be used:
Form for reporting under Article 8(1)(a) of Council Regulation (EU) No 269/2014
The reporting form is submitted to Banka Slovenije on its agreed website for secure data exchange box.bsi.si. For other correspondence, email sankcije@bsi.si.
Before the reporting form is submitted to Banka Slovenije, the frequently asked questions on freezing of funds on the European Commission website should be consulted.
Reporting by natural and legal persons, entities and bodies that own, hold or control assets and reserves of the Central Bank of Russia
In accordance with Article 5a(4a) of Council Regulation (EU) No 833/2014, natural and legal persons, entities and bodies, including the ECB, national central banks, financial sector entities, insurance and reinsurance undertakings, central securities depositories and central counterparties must provide, no later than two weeks after 27 April 2023, to the competent authority of the Member State where they are resident or located, and simultaneously to the European Commission, information on the assets and reserves referred to in Article 5a(4) that they hold or control or are a counterparty to. This information is updated every three months, and covers at least the following:
- information identifying the natural or legal persons, entities or bodies owning, holding or controlling such assets and reserves, including the name, address and VAT registration or tax identification number;
- the amount or market value of such assets and reserves at the date of reporting and at the date of immobilisation;
- the types of the assets and reserves, broken down according to the categories set out in points (i) to (vii) of Article 1(g) of Council Regulation (EU) No 269/2014, as well as cryptoassets and other relevant categories, and an additional category corresponding to economic resources within the meaning of Article 1(d) of Council Regulation (EU) No 269/2014. For each of those categories, where available, relevant features such as quantity, location, currency, maturity and contractual terms between the reporting natural or legal person, entity or body and the asset owner should be indicated.
For ease of reporting this information, the reporting form below should be used:
Form for reporting under Article 5a(4a) of Council Regulation (EU) No 833/2014
The reporting form is submitted to Banka Slovenije on its agreed website for secure data exchange box.bsi.si. For other correspondence, email sankcije@bsi.si.
Before the reporting form is submitted to Banka Slovenije, the frequently asked questions on the Central Bank of Russia on the European Commission website should be consulted.