Attached are links to the press reports (here and here) of several prosecutions initiated by the Latvian law enforcement authorities in connection with the alleged breach of a prohibition set out in Article 5n of Regulation 833/2014. This prohibition (among others) prohibits EU citizens or residents to provide certain professional services listed therein to Russian state bodies or Russian companies, even if the relevant recipients of the services are not subject to any sanctions.
The relevant articles are short of details (one refers to project management services, which is not listed as prohibited activity in Article 5n of Regulation 833/2014). Likely the breach was alleged in connection with the provision of “business and management consulting” services to non-sanctioned Russian entities.
The breach was alleged in connection with Latvian residents/nationals: (i) organising at least 5 events (forums) that took place in Moscow; and (ii) holding the positions of Advisor to the General Director, Chief Financial Officer and Chief Economist.
The matter is of practical relevance, because many Russian citizens maintain relationships with their employers in Russia while residing in the EU. Being the EU residents they need to reassess wether their relationships need to be discontinued or modified given the restrictions set out in Article 5n. Further, the wide terminology used in Article 5n creates the risk of its wide application.