- How do I get transparency as quickly as possible about the impact of sanctions and rising energy prices on my business model and on my cash flow, P&L and balance sheet?
- How are the effects manifested in different scenarios and what countermeasures can be initiated?
- How do I control communication with the relevant stakeholders (especially banks)?
- How can your company react to disrupted supply chains in the short term and what might long-term changes look like?
Your contact: Dr.-Ing. Sylvia Trage, Director, Consulting, Value Chain Transformation
- Under what conditions may employees fleeing Ukraine work in Germany or other countries for a limited period of time?
- Are there countries in the EU that have simplified procedures for residence/work permits or visas (e.g. remote working visas, digital nomad visas or similar)?
- What is the insurance status of Ukrainian citizens if they are temporarily staying or working in Germany or other EU countries?
- With which countries does Ukraine have a social security agreement?
- What are the tax consequences if employees who have fled Ukraine work in Germany?
- Can Ukrainian employees work in Germany or other EU countries even if the employer does not have a branch there?
Your contact: Dr. Tobias Preising, Partner, Tax, Global Mobility Services
- What are the effects of the "Ukraine war" event on reporting?
- Is it necessary to adjust estimates or valuations?
- What are the effects on company valuations or the going concern assumption?
- What impact could the Ukraine war have on consolidated accounts?
Recommendations for action:
- Consider the legal requirements regarding the reporting of an "event of particular importance" (Section 285 No. 33 or Section 314 Para. 1 No. 25 HGB) or a significant event (IAS 10.21) and review existing country-specific information or information on customer concentration risks (IFRS 8.33-34)
- Evaluate reporting obligation in the risk report and changes in forecast reporting
- Review estimates or judgements made for financial statements to determine the influence of the Ukraine war and document the basis for the decision in detail (see also Guide - Annual financial statements: The advantages of meaningful documentation - KPMG AG Wirtschaftsprüfungsgesellschaft)
- Review planning assumptions and parameters for company valuations and consider the reporting date principle
- Analyse in detail relevant parent-subsidiary relationships with regard to control over the subsidiary and any necessary changes in consolidation
Your contact: Johann Schnabel, Partner, Audit, Head of Accounting & Process Advisory in Germany
Industrial companies should in the short-term
- Identify deals with Russia or Russian business partners who are subject to economic sanctions;
- Evaluate whether sanctions are relevant for specific business transactions or relationships;
- Act quickly and initiate appropriate measures, such as submitting an application to the Federal Office of Economics and Export Control (BAFA) or terminating the business relationship (individual case-by-case decision).
- Financial sector companies should take the following short-term actions
- conduct an impact analysis to determine the affected business areas and the intensity of the impact;
- check the settings in the sanction filter and in transaction monitoring;
- review existing customer relationships, in particular correspondent customer relationships and securities exposures;
- review relevant documentary transactions;
- revise the current business policy.
- Barbara Scheben, Partner, Head of Forensic, Head of Data Protection
- Alexander Geschonneck, Partner, Forensic, Member KPMG Global Forensic Steering Group
- Timo Purkott, Partner, Financial Services
- Anne-Kathrin Gillig, Partner, KPMG Law Rechtsanwaltsgesellschaft mbH*
An overview of sanctions can be found here.
Since the outbreak of the Russia-Ukraine war, the European Union has imposed various sanction packages on the Russian Federation and Belarus.
These sanctions target sales, exports and various other transactions, including services and financial services related to certain goods where these are to be delivered directly to Russia or Belarus or used in either of those countries.
In addition, a large number of people, organisations and institutions have been included in sanctions lists; their assets have thus been frozen and it is forbidden to provide them with any economic resources. This immediately impacts business partners directly included in these lists and also indirectly affects business partners who are owned or controlled by such listed persons.
Customs processing of exports to Russia or related to Russia involves various internal checks, and appropriate measures must be taken. In particular, the information must be maintained in all relevant systems.
Short-term and medium-term effects
The sanctions now in force directly impact business transactions with Russia and Belarus. As a short-term measure, therefore, all transactions relating to Russia, Belarus and Ukraine must be examined in detail and compliance with existing sanctions must be ensured. In the medium and long term, it remains to be seen how the existing sanctions will evolve. Further sanctions have already been announced. However, it can already be seen that companies are focusing increasingly on export control compliance.
- Does my article or material master include goods that are affected by the sanctions against Russia?
- Does my internal know-your-customer process also enable the identification of transactions that are only indirectly prohibited due to listed persons owning or controlling unlisted business partners?
- How can customs clearance be ensured for transactions related to Russia and Belarus?
Short-term recommendations for action
- Examine material and article master to identify any goods-related prohibitions and approval requirements in relation to Russia and Belarus
- Identify all transactions related to Russia and Belarus and implement country-specific (system-based) blocks
- Perform detailed business partner check and review customs processing