On 30 August 2022, the European Commission updated their FAQs on asset freeze and prohibition to make funds and economic resources available.

The FAQs have been updated to include the following question and answer:

Does a listing affect the status of a beneficial owner of a legal person ?

EU sanctions are temporary measures that do not entail expropriation or modification of the ownership, and the status of beneficial owner does not cease to exist in the moment the beneficial owner is listed. As defined in the Council Regulation (EU) No 269/2014:

• The ‘freezing of funds’ means preventing any move, transfer, alteration, use of, access to, or dealing with funds in any way that would result in any change in their volume, amount, location, ownership, possession, character, destination or any other change that would enable the funds to be used.
• The definition of ‘funds’ includes publicly – and privately – traded securities and debt instruments, including stocks and shares.

It follows that the listing of an individual, as such, should not result in any change to the information held by national beneficial ownership registers.