As a regulated financial institution located in the European Union, KfW must ensure that all its financing fully complies with applicable regulations, including the restrictive measures of the European Union. Russia’s invasion of Ukraine has resulted in a new sanctions regime of unprecedented scope, complexity and volatility. KfW is therefore reminding all its partners of ensuring adherence to the Compliance Annex attached to all of KfW’s financing agreements, which includes the requirement to comply with European Union sanctions. KfW is analysing the impact of new European Union and other sanctions on an ongoing basis and expects its partners to do the same.

Based on various EU sanctions provisions (including Article 5k of Regulation 833/2014) bidders, subcontractors, and suppliers located in or originating from the Russian Federation must be excluded from procurement processes utilising KfW funds.

Russian bidders, subcontractors and suppliers are to be understood as

a) Russian nationals or natural or legal persons, entities or bodies established in Russia,
b) any legal person, entity or body in which more than 50% of the shares are owned directly or indirectly by one of the entities referred to under point (a), 
c) any natural or legal person, entity or body acting on behalf of or at the direction of any of the entities referred to under point (a) or (b).