Ukraine developments

Ireland's IFS sector is a significant constituent of the global financial community and an integral part of the ecosystem supporting and enforcing the sanctions of the EU and its global partners to degrade Putin's military aggression against the people of Ukraine. The initial sanctions that have been signalled involve the Irish IFS and aviation finance sectors and will involve detailed KYC ('Know Your Customer') applications to design forensic sanctions with maximum effectiveness that limits the inevitable costs to sanctioning states and other innocent parties, including Russian citizens themselves. This will mean targeted effectiveness particularly towards the economic community surrounding Putin, and calibrated targeting of the most effective elements in introducing a shutting out of Russian financial elite and banking elements in SWIFT system sanctions, for example.

On February 24th the Taoiseach Micheal Martin said: 'We will support the imposition of comprehensive and severe sanctions on Russia'. The Irish Government, representatives of the Government parties, and opposition TDs have declared support for the fullest sanctions to be introduced by the EU. This will oblige financial institutions domiciled in Ireland and other IFS companies to provide their support for the sanctions as they are implemented.


An assessment of the scale of Ireland's Direct Financial Links to Russia by Economic Sector was published by the Central Bank of Ireland on March 4th.

Focussing primarily on the breakdown of assets held, the study found that the overwhelming proportion of such Russian linked assets are held in Special Purpose Entities (SPEs), specifically 33 identified remaining, as of December 31st 2021. (By contrast private Irish households held just €1 million worth of Russian assets). The total value of Russian assets in Irish SPEs has dropped by more than a third since 2016, the study shows, from c.€57 billion, to €37.1bn at the end of December 2021. "The assets and number of Russian sponsored SPEs have declined since 2016, largely due to vehicles sponsored by banks, with some unable to issue new debt after the introduction of sanctions in 2014.", the paper says.


The paper identified €49 billion of Russian assets, (aside from the aforesaid €1m in household assets), on the balance sheets of Irish incorporated structures, including Investment Funds, (€11bn, out of a total of €3.8 trillion), insurance and pension funds, and direct bank lending, mostly by Irish incorporated international banks (€1.1bn).

Proportionally, the Russian SPE exposure (€37 bn in 33 vehicles) is a small fraction of the total number and value of Irish SPEs (33 out of 1,800 SPEs in Q4 2021, or 1.8%). By value this represented 3.6% of the total value of SPEs in Ireland at December 31st of €1.03 trillion.


A number of Irish firms in the professional services and IFS space have initiated actions since the invasion to distance themselves from Russian business and oligarch connections in line with international sanctions as the Russian invasion of Ukraine continues.