As of July 2024, there were 46,000 companies operating in the EU countries that are more than 40% directly or indirectly owned by Russian legal entities or individuals, including those with dual citizenship, Moody's reports.
Most of them are registered in the Czech Republic (12.4 thousand), Bulgaria (9.5 thousand), Germany (4.2 thousand), Latvia (3.3 thousand) and Italy (2.5 thousand).
The rating agency notes that banks and financial institutions in these countries must pay "special attention" to their transactions involving such companies and report on them.
Moody's notes that, according to the decision of the European Commission, from July 2024, credit and financial institutions in the EU must comply with new reporting requirements for financial transactions of Russians. They must report to the competent authorities transfers of more than €100 thousand from the EU to third countries if they are made by companies with a Russian shareholding of more than 40%. The requirement was introduced as part of the 12th package of EU sanctions against Russia due to military actions in Ukraine. EU member states will study the information "to identify potential violations or circumvention of sanctions."
Russian authorities consider the sanctions illegal and demand their lifting.
In July, the Working Group of Advisers on Foreign Relations (RELEX, a body at the Council of the EU) clarified the criteria for determining ownership and control over a company. Previously, it was considered that a sanctioned person controls a company if he owns more than 50% of the capital. Now it is enough for him to own 50% of the company's capital. This rule is similar to the principle of the Office of Foreign Assets Control (OFAC) of the US Treasury Department. Experts believe that the clarifications are aimed at organizations whose owners deliberately exempted them from restrictions.