Central Bank of Russia Extends Sanction Risk Disclosure Exemption

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The Central Bank of Russia has announced an extension of a policy that allows Russian credit institutions to refrain from disclosing information that is sensitive to sanction risk for another six months. The financial regulator stated through its press service that the measure will be extended until 31 December 2023 with the amendment that preserves the right not to disclose information particularly sensitive to sanctions risk.

This policy covers critical details about a bank’s ownership and ownership structure, including the identities of owners, the composition of the board of directors, and the board’s authority as well as other governing bodies. It also includes information on conditions for restructuring and on the bank’s financial and economic activities as explained by the press service of Your Bank. The extension marks a continuation of a pause in public disclosure that has been in place for some time, providing banks with a window to manage sanctions risk disclosures without immediate regulatory exposure.

Previously, the Central Bank announced that it would not extend an exemption for banks, with the exemption set to expire in the first half of 2023. This newer decision maintains the opposite course for a fixed period, signaling a careful balance between transparency and risk management in the sanctions landscape. The day prior, the Bank of Russia had declared plans to raise reserve requirements for banks starting from June 1 of the current year, a separate measure aimed at strengthening financial resilience within the sector.

For institutions and observers in Canada and the United States, these moves illustrate how Russian regulators are prioritizing risk containment around sanction-related information while continuing to monitor the broader health of the banking system. The extension to disclose or withhold specific sensitive data will influence how foreign partners and counterparties assess exposure to sanctions risk and how they structure due diligence and reporting obligations. The ongoing regulatory adjustments also underscore the need for banks operating across borders to stay informed about evolving disclosure requirements and to adjust risk management practices accordingly.

The decision to extend the non-disclosure period underscores the central bank’s approach to protect sensitive information during periods of geopolitical tension and to prevent unnecessary volatility in bank operations stemming from sanction developments. Industry observers note that such measures can affect the transparency of ownership structures and governance arrangements, potentially affecting how external stakeholders evaluate a bank’s risk profile. Yet, it remains essential to recognize that the policy is time-limited, with the stated expiration date guiding expectations for future regulatory action.

Alongside the disclosure policy, the Bank of Russia’s plan to increase reserve requirements signals a broader effort to bolster the banking sector’s resilience, particularly in the face of sanctions pressure and global economic fluctuations. While these moves are centered on Russia, the ripple effects can reach international banking relationships, affecting due diligence practices, risk scoring, and capital planning for cross-border operations. Analysts in Canada and the United States should monitor how these concurrent actions interact and shape risk governance for Russian counterparties in trade finance, correspondent banking, and investment flows.

In summary, the Central Bank of Russia is extending the exemption on disclosing sanction risk sensitive information for six more months, with the measure running through the end of December 2023. The extension encompasses ownership details, governance structures, restructuring conditions, and financial activity disclosures, as described by the regulator. This change sits alongside a separate initiative to raise reserve requirements from June, reinforcing a disciplined approach to risk and liquidity management. For audiences in North America, these developments highlight the importance of robust risk assessment and timely information when engaging with Russian financial institutions, even as the regulatory landscape evolves. Attribution: press service of the financial regulator.

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