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Sanctions-related reporting obligations

Moody's maintains two sanctions-related reporting obligations files that allow for effective decision-making in compliance processes:

  • The Moody's 40% Russian Ownership File (EU-only) is a file containing EU entities whose proprietary rights are directly or indirectly owned by 40% or more by: a legal person, entity, or body established in Russia; a Russian national; or a natural person residing in Russia.

  • The Moody's 50% Russian Ownership File (non-EU) is a file containing non-EU entities excluding Russia whose proprietary rights are directly or indirectly owned by 50% or more by: a legal person, entity, or body established in Russia; a Russian national; or a natural person residing in Russia.

The sanctions-related reporting obligations files are created by performing effective ownership calculations on ownership data sourced from the Moody's Orbis database. The calculations are designed to capture all ownership interest within the database as defined above, including aggregate and cumulative.

The files are updated and delivered monthly based on new ownership calculations.

Criteria for including an entity in the files

Effective ownership is calculated bottom-up through the key ownership tree, looking for EU or non-EU entities with relevant parent entities that meet the relevant regulation of 40% or 50% effective ownership.

The following criteria are used for including entities in the Moody's 40% Russian Ownership File (EU-only):

  1. The company is an EU company.

  2. The company is effectively owned 40% or more by: a legal person, entity, or body established in Russia; a Russian national; or a natural person residing in Russia.

The following criteria are used for including entities in the Moody's 50% Russian Ownership File (non-EU):

  1. The company is not an EU company or a Russian company.

  2. The company is effectively owned 50% or more by: a legal person, entity, or body established in Russia; a Russian national; or a natural person residing in Russia.

The following examples illustrate the bottom-up approach to finding entities that may or may not be more than 40% owned by Russian entities and consequently included in the Moody's 40% Russian Ownership File (EU-only). Note that the same approach is followed for the Moody's 50% Russian Ownership File (non-EU), using the criteria described above.

Example: Direct ownership

In this example of direct ownership, company A is an EU company and is 40% owned by the Russian entity RU.

Sanctions-related reporting obligations example of direct ownership

Company A is therefore included in the Moody's 40% Russian Ownership File (EU-only) because it is an EU company and the effective ownership by the Russian entity RU into company A is 40%, which meets the 40% threshold.

Example: Indirect ownership

In this example of indirect ownership:

  • Companies A, B, and C are EU companies.

  • Russian entity RU directly owns 80% of company A.

  • Company A owns 50.01% of company B.

  • Company A owns 30% of company C.

Sanctions-related reporting obligations example of indirect ownership

Company A is included in the Moody's 40% Russian Ownership File (EU-only) because it is an EU company and the effective ownership by the Russian entity RU into company A is 80%, which meets the 40% threshold.

Company B is included in the Moody's 40% Russian Ownership File (EU-only) because it is an EU company and 50.01% owned by company A, which is 80% owned by the Russian entity RU. The effective ownership by the Russian entity RU into company B is 50.01% * 80% = 40.008%, which meets the 40% threshold.

Company C is not included in the Moody's 40% Russian Ownership File (EU-only) because it is only 30% owned by company A, which is 80% owned by the Russian entity RU. The effective ownership by the Russian entity RU into company C is 30% * 80% = 24%, which doesn't meet the 40% threshold.

Additional information

In this section: