EU Imposes Measure to Remove 7 Russian Banks from SWIFT Network; New RDIF & Currency Restrictions

March 2, 2022

Today, the European Union imposed a ban on the provision of specialized financial messaging services, including SWIFT interbank messaging network services, to seven Russian banks. The removal goes into effect March 12, 2022 and applies to the listed banks as well as entities directly or indirectly owned 50 percent or more by the banks. All seven of the banks were previously added to western asset freeze lists, barring most business with the banks absent authorization from relevant regulators. The banks currently covered by the ban are:

Bank Otkritie
Novikombank
Promsvyazbank
Bank Rossiya
Sovcombank
VNESHECONOMBANK (VEB)
VTB BANK

Although SWIFT and bank messaging sanctions have generated substantial media coverage, the sanctions imposed by the United States, EU, and others against the Russian Central Bank, western asset freeze sanctions targeting Russian banks, and corresponding Russian currency controls have already significantly impacted Russia’s access to the global financial system.

Subject to certain exceptions and derogations, the EU also imposed the following restrictions today:

A prohibition on contributions to projects financed by the Russian Direct Investment Fund; and
A prohibition on the sale, supply, transfer or export of euro denominated banknotes to Russian individuals and entities, including the government and the Central Bank of Russia, or for use in Russia.

Our team continues to closely monitor the latest developments.