I am informed by the Central Bank that Section 110 firms connected to Russia are estimated to have raised the following funds (sum of all issuances over a year):
|
Year
|
Funds Issued in € Billions
|
|
2017
|
11.10
|
|
2018
|
2.62
|
|
2019
|
6.28
|
|
2020
|
4.27
|
|
2021
|
9.79
|
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.
The Central Bank has also advised that they are unable to provide this detail in relation to Euronext Dublin for the last 5 years as this information is not readily available.
On an aggregate basis, the primary activities of these Russian linked vehicles is to raise financing for Russian companies and banks. The Central Bank does not systematically identify nor monitor the use of proceeds of the fundraising by section 110 vehicles. However, I am informed by the Central Bank that while it considers that there may be some limited linkages to the Russian railway industry it is not aware of any section 110 vehicles, at this point, directly financing the Russian military.
In terms 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.
The Central Bank has consistently engaged with all relevant firms to ensure compliance with the sanctions regime. There has been a significant focus on Russia/Ukraine related issues in supervisory engagements and supervisors incorporate discussions on financial sanctions compliance into their regular supervisory engagements.
In the Central Banks role as Competent Authority for the administration of financial sanctions, it is engaging closely with a number of SPEs with links to Russia. Where it suspects a breach of a sanction, the Financial Sanctions team reports such suspicions to An Garda Síochána.
