Study by the National Council of Notaries: EU sanctions and transactions of Russian citizens
Official study by Consiglio Nazionale del Notariato (Studio n. 199-2022/A) "Effects of EU sanctions on the contractual activities of subjects of Russian nationality and individuals residing in Russia", authored by Daniela Boggiali. Approved by the Commission on European and International Affairs on 12.10.2022.
Official source of the document:The study on the Consiglio Nazionale del Notariato siteverified 2026-09-11
About this document
An official study by the Italian National Council of Notaries (Consiglio Nazionale del Notariato, Studio n. 199-2022/A) on how EU sanctions affect transactions by Russian citizens and persons residing in Russia, approved by the relevant commission in October 2022. Key conclusions: asset freezes apply only to listed individuals, whom the notary must check against the FSF database; for other Russian citizens there is no general ban on buying or selling real estate or holding stakes in Italian companies. At the same time, restrictions applying to all Russian citizens remain: thresholds on bank deposits and bans on certain securities. For Russians buying property or starting a business in Italy this is an authoritative primary source; the sanctions regime changes, so check the current versions of the regulations.
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How to use it
Worth reading before a real estate or company share transaction: you will understand which checks the notary will run and what questions to expect. Sections are organized by transaction type: fund freezes, purchase and sale of real estate, company stakes. You can cite the study number when talking to a bank or notary. The document can be viewed page by page in the protected viewer.
Why you need it
Legal analysis for notaries: can Russian citizens conduct real estate transactions, participate in the creation/acquisition of company shares in Italy. Relevant for relocating Russians buying property or starting a business in Italy.
Key information
- Asset freeze: only for individuals on sanctions lists (Decision 2014/145/PESC). Notary must check via FSF (Financial Sanctions Database): https://webgate.ec.europa.eu/fsd/fsf
- For non-sanctioned Russian citizens: there is NO general prohibition on buying/selling real estate or participating in companies
- Restrictions for all Russian citizens: prohibition on bank deposits above certain thresholds; prohibition on purchasing EU securities denominated in euros issued after 12.04.2022; a number of sectoral prohibitions
- Structure of the study: asset freeze (p. 1); real estate transactions - purchase (p. 3) and sale (p. 4); acquisition/disposal of company shares (p. 5)
- Procedure for notary: 1) check the sanctions list FSF; 2) assess whether the transaction violates measures applicable to all Russian citizens
Related materials
Reference documents
- Announcement of the free Italian language school Penny Wirton (Turin)
- List of Correspondences of OKSO Specialties (Russian Specialties by Classifiers 1987-2013)
- Presentation of the project "Sentimenti" - Russian-speaking community on the coast of Italy
- Recognition of foreign driving licenses (Vienna Convention) - excerpt
- Procedure for registering in the online accounting service for Partita IVA (FlexSuite, steps 02-05)
- Clarification from the Italian Ministry of the Interior: BE license and restrictions for novice drivers (Art. 117 CdS)
A real document from community materials. Not legal advice - verify the official blank and current requirements on the authority site (esteri.it, interno.gov.it, portaleimmigrazione.it, questure.poliziadistato.it).