The list of sanctions includes some types of services, about which the media has practically written nothing, but which are used by many entrepreneurs when structuring their business.
Among other things, on June 3, 2022, the Council of Europe adopted a decision to amend Regulation No. 833/2014, which deals with restrictive measures related to Russia's activities in Ukraine.
Link to the decision of the Council of Europe - Publications Office (europa.eu)
According to these measures, from 5 July 2022 it is prohibited to act or arrange for another person to act as a trustee, variable shareholder, director or secretary or in any other similar capacity of a trust or similar legal entity for the benefit of the following persons:
a) Russian citizen* or person living in Russia**;
b) a legal entity established in Russia;
c) a legal entity whose ownership rights are more than 50% owned by the person referred to in points a and b;
d) a legal entity that is more than 50% controlled by the person referred to in points a and b or c;
e) a legal or natural person acting on behalf of or under the direction of the person referred to in point а, b, с, or d.
It must be considered that acting as a “nominal” shareholder of the company without receiving payment for this service (so-called through friendship) is still subject to these restrictive measures (as well as mediating the mentioned activity) and may be punished for violating the sanction:
(As of 2022, 1 fine unit in Estonia is 4 euros)
From the same date (07 May 2022), it is prohibited to provide accounting, auditing (including mandatory audit directly or indirectly), tax consulting, business or management consulting or public relations services:
Since 7 October 2022 these restrictions in Council Regulation (EU) No 833/2014 expanded on legal, IT consulting, architecture, and engineering services
It should be noted that above restrictions shall not apply to
*Does not apply to persons who have a residence permit of an EU member state.
**There may also be persons who do not have the citizenship of the Russian Federation