On December 18, the government published a European Commission notice (dated December 16) containing guidance on implementing certain provisions of EU Regulation 833/2014.

The notice explains that the Regulation relates to restrictive measures targeting sectorial co-operation and exchanges with the Russian Federation including, among other things, measures aimed at limiting access to EU capital markets for Russian State-owned financial institutions. The guidance is designed to help national authorities and other relevant parties (including EU financial institutions) to implement the Regulation in a uniform manner.

The guidance takes the form of answers to certain questions that have been brought to the Commission’s attention. In relation to the financial services measures, the Q&As cover trade finance, emergency funding, loans (other than for trade finance or emergency funding), and capital markets.