EBA Guidelines on ensuring compliance with EU and national restrictive measures – applicable from 30 Dec 2025

On 14 November 2024, the European Banking Authority (EBA) issued the following guidelines:

• EBA/GL/2024/14 on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures.
• EBA/GL/2024/15 on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures under Regulation (EU) 2023/1113¹.

The FIN-FSA has notified the EBA it intends to comply with both Guidelines.

In accordance with Article 16(3) of the EBA Regulation², financial institutions must make every effort to comply with EBA guidelines.

Content and scope of application of the Guidelines

The EBA Guidelines provide uniform standards for the internal governance, policies, processes and controls of institutions within their scope of application. The objective is that, by complying with the Guidelines, these institutions are able to ensure the implementation of Union and national restrictive measures.

The EBA Guidelines apply to financial institutions, payment service providers, electronic money institutions and crypto-asset service providers as follows:

1. Guidelines EBA/GL/2024/14 establish internal policies, procedures and controls for financial institutions subject to regulation and supervision under Directive 2013/36/EU (Capital Requirements Directive, CRD IV), Directive (EU) 2015/2366 (Second Payment Services Directive, PSD2) and Directive 2009/110/EC (Electronic Money Directive, EMD).
2. Guidelines EBA/GL/2024/15 establish internal policies, procedures and controls that should be adopted by payment institutions and crypto-asset service providers to ensure the effective implementation of Union and national restrictive measures when performing transfers of funds or crypto-assets under Regulation (EU) 2023/1113. 

Entry into force

The EBA Guidelines apply from 30 December 2025.

Amendments to FIN-FSA regulations and guidelines

The FIN-FSA will make the necessary amendments related to the abovementioned EBA Guidelines to its regulations and guidelines 4/2023 Customer due diligence related to compliance with sanctions regulation and national freezing orders.

For further information, please contact

Anssi Leisio, Chief Specialist, telephone +358 9 183 5524 or anssi.leisio(at)fiva.fi

Appendix

EBA’s guidelines 

See also

FIN-FSA website: Guidelines of the European Supervisory Authorities

¹Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849 (Text with EEA relevance)
²EBA Regulation (EU) No 1093/2010