Ireland tells crypto firms how to handle transactions caught by EU Russia sanctions

DUBLIN, Sept. 26, 2026 — The Central Bank of Ireland has issued guidance to crypto-asset service providers, or CASPs, clarifying their obligations under EU sanctions against Russia, particularly transaction bans under Council Regulation (EU) No. 833/2014.

The guidance highlights Articles 5ad, 5ba and 5bb, while stressing that the list is not exhaustive and firms remain responsible for keeping abreast of changes to EU and other applicable sanctions regimes.

Following discussions with the European Commission, the central bank said that where technical constraints make it impossible for an EU CASP to reject an incoming transaction from an entity covered by a transaction ban, the CASP should hold the assets rather than return them to the sending party. Returning assets directly or indirectly to an entity covered by the ban would breach Regulation 833/2014.

Assets may, however, be returned in certain circumstances after appropriate due diligence establishes that no sanctioned entity or platform would be involved. The guidance gives the example of a sender providing a verified address that is unaffiliated with the prohibited platform. Transactions should be assessed individually for direct and indirect involvement of listed persons or entities.

CASPs should report relevant information to the national competent authority within two weeks of acquiring it. The central bank stressed that the Commission position underlying the guidance is an informal interpretation, with only the Court of Justice of the European Union able to provide a binding interpretation of EU law.

In Ireland, CASPs identifying breaches or potential circumvention of the transaction bans must report them to the Central Bank of Ireland and separately to An Garda Síochána. Reports to the central bank should be made using the Financial Sanctions Return through its external portal.

The regulator acknowledged that the existing return was not designed for some CASP-specific circumstances and told firms to complete it on a best-efforts basis in the interim. It is developing an updated form intended to better accommodate CASP reporting requirements.

The clarification adds to Ireland’s sanctions compliance framework, under which the central bank administers financial sanctions and requires regulated firms to monitor transactions and comply with applicable EU restrictive measures.