Reviews undertaken by the Central Bank of Ireland have identified just under 2% of the 3,000 Special Purpose Entities (SPEs) in Ireland as having links to Russia. It is currently estimated that about one in three of those (that is, 17 SPEs, being 0.5% of the total SPE population) is directly linked to individuals in scope of the sanctions regime.
A Central Bank statistical release on the direct financial links to Russia by economic sector, issued on 4th March and incorporating the latest available data on financial services sectors, stated that, at end-2021, SPEs had holdings of €37.1 billion of Russian-issued assets. There were 33 Russian sponsored SPEs identified with total assets of €35.5 billion, accounting for 8% of the non-securitisation SPE sector.
Year
|
Total Assets in €bns
|
No. SPEs
|
No. Russian Connected SPEs
|
2017
|
732.3
|
2,092
|
73
|
2018
|
734.5
|
2,356
|
65
|
2019
|
872
|
2,631
|
64
|
2020
|
942.1
|
2,862
|
62
|
2021
|
1031.8
|
3,133
|
59
|
For the purposes of the above table, the Central Bank has classified an entity as a Russian Connected SPE if they meet any of the following criteria: The entity is ultimately controlled by a Russian company or individual; The entity has assets with a Russian counterparty or issued by a Russian counterparty; the entity owes money to a Russian counterparty.
Irish SPEs are fully in scope of the sanctions regime. A breach of financial sanction is a criminal offence. Accounts, funds or other assets must be frozen without delay so that they cannot be made available, directly or indirectly, to the sanctioned person, entity or body. In the Central Bank of Ireland’s role as Competent Authority for the administration of financial sanctions, the Central Bank is engaging closely with a number of SPEs with links to Russia. Where the Central Bank suspects a breach of a sanction, the Central Bank reports such suspicions to An Garda Síochána.