Dáil Éireann Debate, Tuesday - 29 September 2026
317. Deputy Malcolm Byrne asked the Tánaiste and Minister for Finance if his attention has been drawn to efforts by Russia or Russian backed financial technologies or financial companies, to move money through financial institutions based in Ireland in breach of sanctions; and to outline the measures in place to prevent such actions. [68220/26]
Amharc ar fhreagraThe Deputy will be aware that in response to Russia’s illegal invasion in Ukraine, the EU has adopted a number of EU Council Regulations (the “EU Regulations”) which comprise targeted financial sanctions against a number of individuals, bodies and corporate entities (“Designated Persons”). Sanctions have direct effect in all Member States of the EU, and they are legally binding on all natural and legal persons in Ireland. As such, a natural or legal person who contravenes a provision of an EU sanctions regulation would be guilty of an offence and liable to prosecution.
While EU Regulations have direct effect, each Member State is required to create offences and lay down penalties applicable to infringements of the EU Regulations in domestic law. My Department plays an important role in relation to sanctions policy, and it, alongside the Department of Enterprise, Tourism and Employment, is responsible for preparing the requisite Statutory Instruments to establish these offences and give effect to the penalties.
Consequently, it is a criminal offence to transfer funds, to make funds or economic resources available, directly or indirectly, or to provide services that are prohibited under the Regulations, to Designated Persons. Additionally, accounts, funds and other assets owned, held or controlled by Designated Persons must be frozen without delay so that they cannot be made available, directly or indirectly, to Designated Persons.
If a person is involved in a breach of the EU Regulations they are guilty of a criminal offence. Furthermore, where an offence under the EU Regulations is committed by a corporate entity and is proved to have been so committed with the consent or connivance of or to be attributable to any neglect on the part of any person, being a director, manager, secretary or other officer of the corporate entity, or a person who was purporting to act in such capacity, that person shall, as well as the corporate entity, be guilty of an offence. All persons must supply any information related to suspected financial sanctions breaches to An Garda Síochána pursuant to the relevant EU Regulations.
The Central Bank of Ireland is one of three Competent Authorities in Ireland, the others being the Department of Foreign Affairs and Trade and the Department of Enterprise, Tourism and Employment, for the administration and enforcement of sanctions, or restrictive measures.
The Central Bank is responsible for the administration of financial sanctions. In administering financial sanctions, the Central Bank undertakes the following:
• Receives notifications from the financial services industry of assets/funds that have been frozen under the sanctions legislation. In this regard all natural and legal persons, entities and bodies are required to report to the Central Bank information on assets held by them on behalf of individuals or entities that are subject to the asset freeze. The Central Bank collates the reports of frozen assets for onward transmission to the Department of Foreign Affairs and Trade and the EU Commission.
• Receives and analyses transaction reports from certain Russian linked firms operating in Ireland. Where there are suspicions of breaches or where potential circumvention of Sanctions is identified, the matter is referred to An Garda Siochana.
• Assesses applications for derogations that are permitted under the restrictive measures legislation in respect of financial sanctions.
• Engages with the other domestic competent authorities and the European Commission to ensure that restrictive measures and financial sanctions are being implemented correctly and consistently.
In addition to the above, I understand that under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, those with obligations regarding anti-money laundering and countering the financing of terrorism, which includes financial institutions, must, inter alia, assess risks, carry out customer due diligence, verify customer and beneficial owner identities, conduct ongoing monitoring of transactions and report suspicious transactions.
The Central Bank of Ireland implements a risk-based approach to the anti- money laundering and countering the financing of terrorism supervision of credit and financial institutions. Effective risk-based supervision entails identifying money laundering and terrorist financing risks, supervising firms commensurate with the risks identified and taking necessary action to bring about compliance. All credit and financial institutions must comply with their statutory obligations and must be able to demonstrate to the Central Bank how they have complied.
Finally, Ireland supports strong and robust sanctions in response to Russia’s illegal aggression in Ukraine. The targeted sanctions adopted in response to Russia’s actions in Ukraine are the most expansive and hard-hitting sanctions in EU history. An unprecedented range of sectoral restrictions against Russia have been adopted, including measures targeting trade, finance, energy, technology, defence and maritime sectors. These sanctions are putting the Russian economy under serious strain and reducing its ability to finance its war effort.
Ireland’s Presidency of the Council of the EU has prioritised maintaining and increasing the pressure on Russia, including through the adoption of the 21st package early in our Presidency and the recent extension of the Ukraine Territorial Integrity regime until 2029. This extension will maintain sanctions on some 3,000 individuals and entities responsible for undermining the territorial integrity, sovereignty, and independence of Ukraine.
