Russia is already on the EU blacklist for money laundering and terrorist financing. For Russians living in the EU, this will mean that banks and other financial institutions will subject them to stricter checks and in some cases may refuse to provide services.
In addition, the EU already has a law in effect, according to which any interaction with banks that have fallen under sanctions is considered a crime, which in certain cases can result in up to five years in prison.
Lawyers advise that such accounts be closed, and people declared "foreign agents" can only rely on understanding from European officials: since in Russia "foreign agents" are forcibly obliged to open an account with "Sberbank" and they are not allowed to close it.
What happened?
On December 3, 2025, the European Commission added Russia to the list of countries with a high risk of money laundering and terrorist financing. The European Parliament and the Council of the EU then considered and approved this decision. Today it entered into force.
Since the start of the war in Ukraine, Russia has consistently excluded almost all European countries from the financial data exchange system. This means that the European Union can no longer, as before, in case of suspicions of money laundering, for example, request from Russia information about the bank accounts of specific Russian individuals or legal entities.
Ukraine has been demanding that Russia be included in the "blacklist" of the FATF (Financial Action Group on Money Laundering - an international organization that recommends standards for combating financial crimes) from at least 2023. The group froze Russia's membership in 2023, accusing it of an attack on Ukraine, but did not include it in the "blacklist", although this would have led to significantly stricter checks on the financial transactions of Russians around the world.
The inclusion of Russia in the EU "blacklist" is an attempt to introduce more thorough checks within the European Union itself. It is during such checks that various schemes for circumventing sanctions can be revealed. This is especially important, since by May 20, 2025, all EU countries had to change their national legislation, strengthening penalties for violating the sanctions regime.
Since 2014, after the annexation of Crimea by Russia, interaction with legal entities and individuals subject to sanctions has been prohibited in the EU. After the start of the full-scale war against Ukraine, the sanctions lists were significantly expanded - for example, many large Russian banks were included in them. But without the exchange of financial information, control over compliance with sanctions is significantly more difficult.
As early as the summer of 2025, it became known that the European Commission was preparing to add Russia to the "black list", which already includes countries such as Afghanistan, Iran, North Korea and Monaco.
What will happen next?
The decision of the European Commission by default does not affect Russians who live and do business in countries outside the "black list", and who use the services of foreign financial institutions - the Commission explained to The Bell (included in the Russian register of "foreign agents"). That is, it follows from this answer that if a Russian citizen lives in the EU and uses the services of local banks, in principle he has nothing to worry about. At the same time, the European Commission specifies that more in-depth checks of financial transactions related to Russia will begin in the EU.
These "enhanced due diligence" are an established term in the banking sector (enhanced due diligence). What exactly they include is decided by each country individually, but their general characteristics are described in Directive 218/943 of the European Parliament and of the Council.
According to it, banks and other financial institutions will require additional information about Russian clients - about the purposes and reasons for the transactions carried out, about the origin of funds and assets; relations with such a client will have to be approved by the senior management of the financial institution, and the frequency and number of checks will increase constantly. The Directive's page shows how each EU country has transposed these requirements into its national legislation.
The European Commission did not respond to additional questions from the BBC. The editorial staff sent more than 40 inquiries to the executive bodies and central banks of the EU countries to clarify what exactly changes with the inclusion of Russia in the "blacklists". Few have responded. From the responses received, it is clear that the countries interpret the rules differently, but Russians who live in the EU or in other countries outside the "blacklist" may also face additional checks.
For example, the Finnish Anti-Money Laundering Act speaks of enhanced checks, and liability for violating sanctions is criminal - according to the Criminal Code of Finland. At the same time, the head of the anti-money laundering department at the Finnish financial regulator FIN-FSA, Pekka Vasara, explains that citizenship of a country from the "blacklist" should not be the only reason for increased checks.
The fact that Russians will be checked more often was confirmed by the German Federal Financial Supervisory Authority, as well as the financial intelligence services of Estonia and Latvia. Latvia also has its own national "black list" of countries - Russia is already included in it.
The information that Russia is on the EU "black list" will also be reflected in the databases of compliance companies. Financial institutions use the services of such companies to check the reliability of their clients. Usually, the system automatically displays a warning next to the client's name - that he or his country is on a sanction or risk list. In such a case, the financial institution either refuses services or requires significantly more information from the client.
Banks outside the EU have also begun to freeze operations of Russian citizens. There are such cases in Armenia and Serbia, and banks in Kazakhstan, Tajikistan and Oman have stepped up checks on transactions of Russians as early as the end of December 2025. This affected both individuals and legal entities.
At the beginning of 2026, it became known that banks in the eurozone had also begun to block transfers of Russian citizens. Problems have arisen with French, British and Finnish financial institutions.
Up to five years in prison for violators
Violating the sanctions can be punishable by up to five years in prison. This follows from Directive 2024/1226 of the European Parliament and of the Council, which introduces minimum EU-wide rules to define criminal offences and penalties for breaching and circumventing EU sanctions.
Although the directive introduces a threshold of €10,000 below which breaches do not necessarily lead to criminal prosecution, Member States can decide to criminalise smaller amounts. In practice, approaches vary - some countries criminalise every breach, others apply a threshold.
Can an account in a bank that has been sanctioned continue to be used?
Russians living in the EU are worried about whether they will be able to use accounts in banks that have been sanctioned. For example, many people use this to pay utility bills and help relatives. Logically, tourists should also fall under the restrictions of Directive 2024/1226.
Estonian Financial Intelligence reminded the BBC that sanctions are mandatory for everyone who is in the EU for any reason, but nevertheless each specific transaction must be considered separately. The Finnish financial regulator FIN-FSA, on the contrary, told the BBC that the restrictions do not apply to tourists, but the final decision remains within the competence of the prosecutor's office.
Some EU countries already know about the Russian accounts of those Russian citizens who have reported them to them — for example, when applying for a visa, such accounts are required to be declared. Of course, a Russian citizen can take a risk and hide this information.
The Finnish Foreign Ministry and representatives of the financial intelligence units of Latvia and Estonia refer to Regulation (EU) 269/2014 on sanctions in connection with the war in Ukraine. It prohibits the provision of any funds or economic resources - directly or indirectly - to individuals and legal entities subject to sanctions.
"In practice, this means that transferring funds to a bank included in the sanctions list is prohibited," the Finnish representatives replied.
These institutions interpret the possible consequences for Russians as follows: if transactions are carried out in Russia, and the account holders are located in the EU - for example, making transfers via a mobile application - this may constitute a violation of the sanctions. The Latvian Financial Intelligence Unit also states the same. According to their interpretation, any operations of a sanctioned bank - incoming or outgoing - violate the law.
"When a person has an account with a credit institution included in the sanctions list, he effectively ensures the availability and accessibility of funds to that sanctioned entity — for example, by paying commissions or other service fees — and such conduct is considered a violation of the sanctions. The same applies when the client holds or deposits funds with such a credit institution, including in the form of a deposit, savings account or other similar product. Possession of any funds or receipt of services from a credit institution included in the sanctions list means providing funds to the sanctioned entity, and such actions are considered a violation of the sanctions. The fact that a person opened a bank account in a sanctioned bank before the introduction of targeted sanctions does not exempt them from the obligation to comply with the current sanctions legislation," the Latvian Financial Intelligence Service believes.
There are also concerns that Russians in the EU may have to obtain permission for almost any action related to a sanctioned bank - if, for example, the account cannot be closed for some reason or is needed to help relatives.
Estonian Financial Intelligence told the BBC that Russians in the EU should indeed be concerned that every transaction may have to be coordinated. The Latvian Financial Intelligence Service clarified that it does not issue permits for routine operations with sanctioned banks, but can only authorize the withdrawal of funds from such a bank to the EU if this is necessary to close the account.
It is not entirely clear what should be done with investment accounts in sanctioned banks. Due to the sanctions, some securities are frozen and their sale is extremely difficult, and without a sale such an account cannot be closed. For example, the Finnish financial regulator FIN-FSA told the BBC that they are aware of this problem of Russians.
Another question is whether it will be considered a crime if a sanctioned bank turns out to be "in the chain" of the transaction — for example, if a Russian citizen sent money from the EU to a Russian sanctioned bank, but the funds first passed through a bank in Georgia.
The Finnish Foreign Ministry and the financial intelligence units of Latvia and Estonia responded to the BBC that each case should be considered individually, but if a non-sanctioned bank in the chain is used to conceal a transaction to a sanctioned bank, such a situation could be considered an attempt to circumvent sanctions (Article 9(1) of Regulation 269/2014).
What should "foreign agents" do?
From 2025, "foreign agents" will be forced to open an account in "Sberbank". The income of these people must pass through this account. There are already over 500 such accounts and they cannot be closed. The BBC has sent dozens of inquiries to the executive authorities of all EU countries, but an answer on what "foreign agents" should do has only come from the Finnish financial regulator FIN-FSA. Their preliminary position is that keeping an account in a sanctioned bank is not prohibited if this account is not used.
Most likely, "foreign agents" will not be considered violators of the sanctions, suggests Marita Gorgiladze. However, it is important that these individuals do not use such an account for financial operations related to the EU.
"The requirement to have such an account arises from the domestic legislation of the country of which they are citizens. The aim of [EU laws] is to punish those who voluntarily support, finance or assist sanctioned organisations, not individuals who were forced to open an account.
Furthermore, the law on "foreign agents" is well known to EU authorities, and they are aware that these people are being persecuted and coerced by the Russian government. It is logical to assume that such individuals should not be considered as violators of sanctions," says Gorgiladze.
She advises "foreign agents" to document everything related to the account in "Sberbank", including evidence that the account was opened forcibly and that it cannot be closed.
What measures should be taken now?
The Latvian Financial Intelligence Service told the BBC that a person must terminate all relations with a sanctioned bank in order not to fall under the criminal provision of the state (Article 84 of the Latvian Criminal Code).
However, it is theoretically possible to keep an account in a sanctioned bank (Article 4 of Regulation 269/2014). In such a case, a person must prove to the EU country in which he lives that his account is necessary for the most basic needs: housing, food, medicine, care for children and other family members. Emergency situations also fall under the exceptions. But all this applies only if it is impossible to open an account in a bank that is not under sanctions.
Marita Gorgiladze advises not to open and use accounts in sanctioned banks and to switch to an institution that is not included in the sanctions lists.
"It is not even clear yet how some terms of the legislation will be interpreted in practice," warns Gorgiladze.
In general, lawyers are of the same opinion: the most effective thing is to close the accounts. Some believe that even the banking application should be deleted. Before closing the account, experts advise to keep all documents that prove the legality of the purposes of operations with a sanctioned bank, to avoid large transfers, not to open new products and not to use services for which the bank will take a commission.
The problem is also complicated by the fact that the State Duma is awaiting its first reading a bill that provides for penalties for entrepreneurs who comply with foreign sanctions. If this document comes into force, such businessmen, for example, may have to hide the reasons why they are closing an account with a sanctioned bank.