Screening of EU sanction lists in relation to the situation in Ukraine

The invasion by the Russian Federation of Ukraine has prompted the European Union (EU) to implement a broad range of restrictive measures that target, amongst others, the financial sector, defense, airspace, energy, and the transport sector. Furthermore, due to the recent participation of Belarus with the Russian Federation in the aggression against Ukraine, the EU has also decided to impose restrictive measures against persons, entities, and bodies from Belarus.

These restrictive financial measures include but are not limited to:

  • A ban on transactions with the Russian Central Bank
  • A SWIFT ban for several Russian banks
  • A ban on certain services and transactions to the Russian Federation or its government; the Central Bank of the Russian Federation, and; entities and bodies acting on behalf of or at the direction of the Central Bank of the Russian Federation
  • Transactions with persons, entities, and bodies that have been listed by the EU

On September 17th, 2021, the FIU-Aruba published a designation by the Head of FIU (Aanwijzing EU Sancties Bevriezingsmaatregelen) of all EU sanction lists in which freezing measures are imposed on persons, entities, and bodies. Therefore, the restrictive sanctions that the EU has imposed on the Russian Federation and Belarus are applicable to the aforementioned designation by the Head of FIU.

Hence, all intended and performed transactions by or on behalf of persons, entities, and bodies that are subject to restrictive measures by the EU are considered unusual and must be reported (promptly) to the FIU-Aruba under indicator 130102.

In light of the volatile situation in Ukraine, the FIU-Aruba reiterates the importance of sanction list screening by service providers. The FIU-Aruba also strongly urges service providers to stay abreast of the latest Decisions and Regulations of the EU (see website: pertaining to restrictive measures against the Russian Federation and Belarus, which are published and amended on an almost daily basis. Service providers can also consult the European Union consolidated sanction list ( for an up-to-date overview of the sanction lists.

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