Sanctions on Russia

Finance

  • 20th package of sanctions against russia

    The EU’s 20th sanctions package against Russia primarily focuses on tightening enforcement rather than introducing entirely new sectoral bans. It deepens financial isolation by targeting additional banks and crypto channels, and places strong emphasis on closing circumvention routes by sanctioning third-country actors and restricting re-exports via countries like Kyrgyzstan. Trade measures expand controls on high-tech and dual-use goods critical to Russia’s military industry, while energy-related steps incrementally increase pressure on oil transport, including the shadow fleet. 

    Highlights:

    • Financial sector measures, including restrictions targeting additional Russian financial institutions and elements of the financial system (including crypto-related activities)
    • Measures targeting crypto-related channels, aimed at limiting Russia’s ability to use alternative financial infrastructure for sanctions circumvention
    • Sanctions on third-country actors (including entities in jurisdictions such as the UAE, China/Hong Kong, and Thailand) involved in facilitating sanctions evasion
    • First use of a country-level anti-circumvention instrument (Kyrgyzstan) to address systematic re-export of sensitive goods
    • Additional listings of entities linked to Russia’s military-industrial complex and supply chains
    • Expanded restrictions on trade in dual-use and advanced technology goods, particularly those relevant for military applications
    • Shadow fleet: designation of additional vessels and related entities, and ban on certain maritime-related services
    • Measures addressing disinformation and propaganda actors linked to the Russian state

    Read more here.

  • Ruble conversion of unfriendly-currency bonds

    Until 31 December 2026, holders are permitted to replace bonds denominated in the currencies of so-called “unfriendly” states with corresponding bonds denominated in rubles, enabling the conversion of foreign-currency debt into domestic-currency instruments.

  • Relaxed borrower assessment in Occupied regions

    In 2026, banks are permitted not to calculate the debt burden ratio of borrowers residing in Russia’s newly incorporated regions, temporarily relaxing standard creditworthiness assessment requirements. This is meant to helps stabilize local economies affected by conflict and isolation but shifts risk to the banking sector and, indirectly, the state.

  • Relaxed criteria for foreign branches of Russian Banks

    When granting permits in 2026 for banks to establish foreign branches, Russian authorities will continue to disregard violations related to participation in deposit insurance systems, maintaining relaxed regulatory criteria for such approvals.

  • Eased entry rules for foreign bank branches

    In 2026, foreign banks are permitted to operate in Russia through branch offices without meeting the previously required minimum credit rating threshold, easing entry and operational requirements for foreign financial institutions.

  • Updated offshore list for financial compliance assessment

    For 2026, Russia updated the list of offshore jurisdictions used to assess whether participants in financial companies comply with regulatory and disclosure requirements. The revised list affects how compliance and eligibility criteria are applied.

  • Key interest rate cut to 16%

    From 22 December 2025, the Bank of Russia reduced its key policy interest rate to 16% per annum, easing monetary policy conditions.

  • Claims against European banks over frozen assets

    The Bank of Russia announced that it will seek to recover losses from European banks through proceedings in Russian arbitration courts, citing the unlawful blocking and use of its assets.

  • EU Uses Article 122 TFEU to Permanently Immobilise Russian Central Bank Assets

    The Council of the EU adopted Regulation 2025/2600 under Article 122 TFEU, allowing it to immobilise Russian Central Bank assets by qualified majority voting rather than unanimity. This legal shift removes the recurring six-monthly renewal requirement that had governed the asset freeze since 2022 and eliminates the risk that a single Member State could veto or allow the measures to lapse.

    For Russia, the consequences are substantial. Approximately €210 billion in Central Bank assets remain locked in the EU on a “temporary but potentially indefinite” basis. Unfreezing is now conditional on Russia ending its war of aggression, paying reparations to Ukraine, and no longer posing serious economic risks to the EU. The decision also lays the legal groundwork for potentially using the immobilised funds to support Ukraine’s reconstruction.

  • Threat of legal action over frozen central bank assets

    The Bank of Russia stated that any use of its assets held in financial institutions of the European Union, including the Euroclear depository, without its consent will be subject to unconditional legal challenge. The Bank reserves the right to implement all available legal and other protective measures to defend its interests, without prior notice.