Circulaire NBB_2025_12 / EBA Guidelines on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures (EBA/GL/2024/14 of 14 November 2024)

Public NBB_2025_12 – 15 October 2025 Circular – Page 1/2 14 Berlaimont Boulevard – 1000 Brussels tel. +32 2 221 38 12 company number: 0203.201.340 RPM Brussels www.bnb.be

Circular
Public
Brussels, 15 October 2025
Reference: NBB_2025_12 your contact:
Nicolas Strypstein tel. +32 2 221 44 74 nicolas.strysptein@nbb.be

EBA Guidelines on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures (EBA/GL/2024/14 of 14 November 2024)

Scope
This circular applies to the following entities:

1. Credit institutions, securities firms 1, payment institutions and electronic money institutions under Belgian law, as well as the foreign branches of the aforementioned institutions;
2. Branches established in Belgium of credit institutions, securities firms, payment institutions, and electronic money institutions subject to the law of States that are not members of the European Economic Area;
3. Financial companies, mixed financial companies and investment holding companies under Belgian law,
   hereinafter collectively referred to as 'financial institutions'.

Summary/Objectives
The guidelines of the European Banking Authority of 14 November 2024 on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures (EBA/GL/2024/14) are integrated into the exercise of the prudential supervision mission of the National Bank of Belgium. These guidelines apply from 30 December 2025. Financial institutions make every effort to comply with these guidelines in accordance with Article 16(3) of Regulation (EU) No 1093/2010 2 and this circular.

1 Including large securities firms that are part of classes 1A and 1B and are subject to the provisions of the banking law.
2 Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Banking Authority), amending Decision No 716/2009/EC and repealing Commission Decision 2009/78/EC.

National Bank of Belgium
Public NBB_2025_12 – 15 October 2025 Circular – Page 2/2

Madam,
Sir,
By this circular, the National Bank of Belgium (the 'Bank') communicates that it integrates the guidelines of the European Banking Authority ('EBA') of 14 November 2024 on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures (EBA/GL/2024/14; the 'guidelines') into the exercise of its prudential supervision mission as referred to in Article 36/2, § 1 of the Law of 22 February 1998 laying down the organic statute of the Bank.

The guidelines state that financial institutions, under the robust corporate governance framework required of them, must in particular:
(1) put in place the appropriate governance framework to ensure the effective implementation of restrictive measures, including the appointment of a senior management member responsible for ensuring compliance with restrictive measures (section 4.1 of the guidelines); (2) assess their exposure to restrictive measures as well as their vulnerability to circumvention thereof (section 4.2); (3) ensure the ongoing effectiveness of policies, procedures and controls regarding restrictive measures (section 4.3); and, (4) regularly train their staff members on this matter (section 4.4).

Securities firms are included by the Bank in the scope of this circular because they are equally subject to the obligation to implement a robust corporate governance framework under Article 17 of the Law of 20 July 2022 3, which constitutes the transposition of the framework of Article 21 of the Law of 25 April 2014 4.
5. The activities of securities firms also expose them, identically, to the risk of attempts to circumvent the application of restrictive measures. Since securities firms are included in the scope of the circular, investment holding companies under Belgian law are also included.

The guidelines are published on the EBA website at eba.europa.eu and are annexed to this circular.
They apply from 30 December 2025. Financial institutions make every effort to comply with these guidelines in accordance with Article 16(3) of Regulation (EU) No 1093/2010 and, for Belgian securities firms and their foreign branches, for branches in Belgium of securities firms subject to the law of States that are not members of the European Economic Area, and for investment holding companies under Belgian law, in accordance with this circular.

A copy of this circular is sent to the commissioner(s), approved auditor(s) of your institution.

Please accept, Madam, Sir, the expression of my distinguished consideration.

Pierre Wunsch
Governor

Annex: 1
Guidelines on internal policies, procedures and controls to ensure implementation of national and Union restrictive measures

3 Law of 20 July 2022 on the status and supervision of securities firms and containing various provisions.
4 Law of 15 April 2014 on the status and supervision of credit institutions.
5 The provision had been made applicable to securities firms by Article 502 of said law, which was repealed by the aforementioned Law of 20 July 2022.