EU bank account for Russian citizens without a residence permit: limits, bans and refusals in 2026

In brief

• Council Regulation (EU) 833/2014 (Article 5b) prohibits EU banks from accepting deposits from Russian nationals and people residing in Russia if their total deposits at one bank exceed EUR 100,000.
• The ban does not apply to EU, EEA and Swiss nationals or to Russians holding a temporary or permanent residence permit in those countries.
• Since 24 October 2025 (the 19th package, Regulation 2025/2033), the same people cannot be issued new payment cards, acquiring, payment initiation services or electronic money. Crypto services are banned entirely.
• The limit applies per bank, not per person; a joint account of two Russian nationals has a ceiling of EUR 200,000.
• Since 29 January 2026 Russia has been on the EU list of high-risk third countries for money laundering. Banks must apply enhanced due diligence, so refusals go beyond what the regulation itself requires.

What Regulation 833/2014 prohibits for Russian nationals and residents

Council sanctions Regulation 833/2014 has been in force since 2014 and has been amended more than 40 times. Several articles concern bank customers from Russia. The main one is Article 5b. Its first paragraph prohibits accepting any deposits from Russian nationals, natural persons residing in Russia, legal persons established in Russia and legal persons outside the EU more than 50% owned by Russian nationals or residents, if the total value of that person's deposits at one credit institution exceeds EUR 100,000.

The second paragraph of Article 5b, as amended by Regulation 2025/2033 of 23 October 2025, prohibits providing the same people with three types of services: crypto-asset services within the meaning of the EU crypto-assets regulation; issuing payment instruments, acquiring and payment initiation; and issuing electronic money. The new wording entered into force on 24 October 2025, the day after publication. The third paragraph lifts all these bans for nationals of EU, EEA countries and Switzerland and for people with a temporary or permanent residence permit there.

Articles 5e and 5f sit alongside. The first prohibits EU central securities depositories from servicing securities issued after 12 April 2022 for Russian nationals and residents. The second prohibits selling them securities denominated in EU currencies issued after 12 April 2022 and fund units exposed to such securities. The exemptions are the same: citizenship or a residence permit in the EU, EEA or Switzerland. Article 5g prohibits nothing but obliges banks to report deposits of Russian nationals and residents above EUR 100,000 to supervisors, and separately to report deposits of Russians who obtained EU citizenship or residence through an investor scheme.

What this means for you. If you hold neither citizenship nor a residence permit of an EU, EEA country or Switzerland, the law does not forbid you from holding an account with an EU bank. It limits the amount, cards and certain services. Everything else is decided by the bank under its own rules. How we work with those rules is described on our page about opening bank accounts, with fact-based expectations rather than promises.

The EUR 100,000 limit: how it is calculated

The European Commission has published more than 40 answers on Article 5b in its sanctions guidance. The latest consolidated version of that guidance was released on 23 October 2026. Together the answers give a clear calculation method.

• The limit is per bank, not per person. The Commission states plainly that the restriction applies per banking licence. Two different banks mean two separate limits. Several accounts at one bank are added together.
• All currencies and all account types. Current, savings and term deposits in any currency count. Financial instruments under MiFID II are not deposits, but the bank assesses each product.
• Branches outside the EU are also bound. A branch of a European bank in a third country remains an EU person and must comply with Article 5b. A subsidiary incorporated under third-country law is not directly subject to EU sanctions.
• Interest and dividends above the limit are not credited. If the balance is already above EUR 100,000, accrued interest may not be accepted. Where it goes is for the bank and the client to agree.
• Old balances are grandfathered. If you held more than EUR 100,000 on 26 February 2022, you may keep, withdraw and spend the money, but you cannot top the account up above the limit. If you held less, you may top it up to EUR 100,000.

Money that does not come from Russia counts too. The Commission specifically answered that a transfer to a Russian national from an account in a third country falls under the limit just like a transfer from Moscow. You may sell a flat in the EU and receive the money to your own account, but if your deposits at that bank are already at the ceiling, the bank will not accept the amount above it. Article 5b does not stop you from buying property in the EU from your own account: it restricts accepting deposits, not using them.

Joint accounts are a separate question. According to the Commission, the limit applies to each holder. If a joint account belongs to two Russian nationals without EU permits, the ceiling at one bank is EUR 200,000. If at least one holder falls under the exemption, for example a spouse with EU citizenship, the restriction does not apply to that account. But the Commission adds at once that a joint account must not be used to circumvent sanctions, which Article 12 of the regulation prohibits. The bank will look at whose money is really in the account. How to plan documents and accounts for spouses and children is covered in our guide to residence for the whole family.

What this means for you. The EUR 100,000 limit does not mean you can safely hold EUR 100,000 in each of ten banks. Formally it is allowed, but each bank checks you separately, and splitting a large sum across many banks looks to compliance like an attempt to get around the rules. I would keep working balances in the EU and plan the main capital where you have a lawful status.

Who a bank treats as a "Russian national or resident"

The regulation uses two criteria, and either one is enough. The first is Russian nationality. It applies wherever the person lives. The Commission answered separately that a Russian national living, for example, in the United States falls under the limit unless they hold a residence permit or citizenship of an EU, EEA country or Switzerland. The same applies to those who moved to the UAE, Serbia, Turkey or Kazakhstan.

The second criterion is residence in Russia. A foreigner without a Russian passport who lives permanently in Russia is also caught. The bank decides this from the address, tax residence, employer and source of income. An EU national who lived in Russia before 24 February 2022 has specific exemptions under some articles of the regulation, but for Article 5b the EU citizenship itself is enough.

Dual nationality works in different ways. A Russian who is also a citizen of, say, Cyprus, Hungary or Portugal is not caught: the Commission confirmed that such an account may be credited above EUR 100,000. A Russian who also holds the citizenship of a country outside the EU, EEA and Switzerland, for example Israel, Turkey or a Caribbean state, remains in scope unless they hold a European residence permit. We wrote about this difference in detail in our article on second passports and banks, and about Russia's approach to holding two passports in the piece on Russian dual citizenship.

For companies the 50% rule applies. A company registered outside the EU, for example in the UAE or Hong Kong, falls under the limit if more than half of its capital is owned directly or indirectly by Russian nationals or residents. The limit applies to each legal entity separately, not to the group. The bans on cards and e-money in Article 5b(2) do not cover such companies unless they are used as a conduit to circumvent sanctions.

What a residence permit gives you and what happens when it expires

A temporary or permanent residence permit in any EU, EEA country or Switzerland lifts the deposit limit, the bans on cards, electronic money and crypto services, and the securities restrictions. Importantly, a permit from one country works in all of them: with a Hungarian permit you are not caught by the limit at a German or Cypriot bank. What counts as a residence permit is decided by each state under its own law. In March 2026 the Commission added that holders of national type D visas who have completed registration where they live are normally considered legally resident and are also covered by the exemption. This concerns visas for study, employment or family reunification, depending on national law.

If the permit expires or is revoked, the exemption stops applying from that moment. The Commission has explained that the bank is not obliged to retroactively block or reduce a balance above EUR 100,000. But from the loss of status it cannot accept new incoming funds if the balance exceeds the limit. Cards follow a stricter rule: when a new card is issued, the residence permit must be valid for the card's entire term. If the permit expires in one year and the card is issued for three, the Commission's guidance says the bank may not issue it.

What remains available after the permit ends? Cards already issued may be used until they expire; the bank does not have to block them. Reissuing and replacing them is prohibited. Access to online and mobile banking continues: the regulation has a specific carve-out for this. Ordinary bank transfers and cash withdrawals are not prohibited by Article 5b(2). Payment service providers must stop prohibited services as soon as they learn of a change in your status, so it is better to renew the permit early and tell the bank about the new card straight away.

Crypto services face the toughest regime. Back in 2023 the Commission explained that crypto accounts of Russian nationals and residents without a paragraph 3 exemption must be closed, not merely frozen for new deposits. Since October 2025 the ban covers all crypto-asset services, not only wallets and custody. If part of your capital is in digital assets, this should be handled together with proof of source of funds; we do this as part of our work with crypto capital.

What this means for you. An EU residence permit removes the sanctions restrictions but not the bank's own checks. Watch the expiry date on your permit card: start renewal early, otherwise the bank may refuse a new card even while your status is valid. I would discuss how European residence programmes work, and which allow you to live without local employment, with a lawyer before choosing a bank.

Why banks refuse even with a residence permit

The law sets a floor, not a duty for the bank to serve you. In practice I see several reasons why a bank declines or closes an account for a client whom the regulation does not restrict at all.

Russia is on the high-risk list. Commission Delegated Regulation 2026/46 of 3 December 2025 added Russia to the EU list of high-risk third countries for money laundering. It entered into force on 29 January 2026. The grounds were the suspension of Russia's FATF membership and deficiencies the Commission found in Russia's anti-money laundering framework. For a bank this means mandatory enhanced due diligence on all business relationships and transactions involving Russia: more documents, senior management approval, ongoing monitoring. Many banks find it easier not to take such a client.

The ban on circumvention. Article 12 of the regulation prohibits knowingly and intentionally participating in activities whose object or effect is to circumvent sanctions. Breaches are punished under national law, and fines for banks can be large. So compliance looks not only at the passport but also at where the money came from, who owns the client's companies and whom the client deals with.

Sanctions and watch lists. The bank screens every client against EU, UN, US and UK sanctions lists and against lists of public officials. A matching surname, a job at a state company or politically exposed person status of a relative can stretch the review to weeks.

The bank's own rules. Many European banks have internal policies on Russia-linked clients: no new clients without a residence permit, a minimum period of residence in the country, no incoming payments from Russia. These rules are not published and they change. A correspondent bank can also matter: if the US or European bank through which payments pass refuses transactions with a Russian connection, your bank will refuse too.

There is a right to a basic account, with a caveat. EU Payment Accounts Directive 2014/92 gives every consumer legally resident in the EU the right to open a basic payment account. This is useful for Russians with a residence permit. But the same directive allows refusal if opening the account would breach anti-money laundering rules. A basic account covers everyday payments, not holding capital.

What this means for you. A bank refusal is rarely about the passport alone. More often the reason is an incomplete file: an unclear source of funds, unexplained transfers from Russia, no link to the bank's country. A well-prepared banking file noticeably improves the odds, but no intermediary can guarantee an outcome.

How the review works and which documents to prepare

The know-your-customer procedure at EU banks follows a similar pattern. First the bank establishes identity and status: passport, residence card or type D visa, proof of address. Then it establishes tax residence and the purpose of the account. The third stage is source of funds and source of wealth: where the money in a particular transfer comes from and how you built your capital overall. For Russian nationals this stage is the most detailed.

The most common bottleneck is the source of funds. The bank must see a chain: earned, declared, transferred. Gaps in that chain, such as cash, crypto sales without history or loans from acquaintances, lead to refusal. How we build such a chain is described on our page about proving the source of funds. Before applying it is useful to run a sanctions check on yourself to learn about list matches in advance.

Options: an EU residence permit, a second citizenship or an account outside the EU

If you need a full European account without limits, there are three lawful routes. The first is a residence permit in an EU, EEA country or Switzerland. It lifts the sanctions restrictions at every EU bank, but requires actually living in the country or at least meeting the renewal conditions. Some investment programmes are closed or harder for Russian nationals, so the programme has to be chosen under the current rules of the specific country. Workable options include Cyprus permanent residence, the Hungarian guest investor programme and residence for financially independent people. How to open an account in Cyprus and Hungary once you have status is covered in our articles on a bank account with Cyprus residence and a bank account in Hungary.

The second route is citizenship of an EU country. It removes all Article 5b restrictions permanently, but it is acquired through naturalisation after many years of residence or by descent. Citizenship of Caribbean countries or Vanuatu gives visa-free entry to the Schengen area but does not lift the limit at EU banks if you remain a Russian national without a European permit. Such a passport does help when opening accounts outside the EU. An overview of programmes is on our citizenship by investment page.

The third route is an account in a country outside the EU. Regulation 833/2014 binds EU persons and does not extend to banks incorporated under third-country law. The UAE, Serbia, Turkey, Georgia and Armenia are not EU members, and their banks operate under their own legislation. That does not mean there are no checks: UAE banks require proof of source of funds themselves and screen clients against international lists, and subsidiaries of European banking groups often apply the parent's policy. How individuals and companies open accounts in the Emirates is covered in our articles on a personal account in the UAE for non-residents and a business account in the UAE, with a comparison of the two countries in Serbia or the UAE.

Also keep in mind the next step in EU regulation. From 2027 the CRD VI directive restricts third-country banks without an EU branch from serving EU residents. If you live in the EU and keep an account in Dubai, this may affect new services. Details are in our article on the CRD VI directive.

What this means for you. An account outside the EU covers holding money and transfers, but it does not give you a European card or local payments. If you live in Europe, you will not get full banking without a residence permit. If you do not, it makes more sense to keep your main account where you are tax resident and hold an EU account up to the limit for expenses.

Where you are tax resident and why the bank asks

Under the CRS standard an EU bank must establish your country of tax residence and report the account to that country's tax authorities if an exchange is in place between them. The bank's country and your country of tax residence are different things. An account in Cyprus does not make you a Cypriot resident, and a Greek residence permit does not exempt you from Russian tax if you spend most of the year in Russia.

In most countries, including Russia, the main test is the 183-day rule. Anyone who spends 183 days or more in Russia within 12 consecutive months remains a Russian tax resident and pays tax on worldwide income, including interest on foreign deposits. How to count days and what to do when relocating is explained in our article on the 183-day rule. For a bank, a contradiction between declared residence and the facts, such as a Spanish permit combined with regular salary transfers from Moscow, is a reason for further questions. Tax residence in the UAE is covered in our article on Emirates tax residency.

One more detail: being tax resident in an EU country while holding only Russian citizenship and no residence permit is almost impossible in practice. To live in the EU for more than half a year you need a status, and that same status lifts the sanctions limit. So the usual order is: status, then tax residence, then the bank.

What to do if you need an EU account

If you would like to go through your situation with a banking specialist, book an online consultation. We will review your status and documents and suggest which bank and which structure fit you. We promise nothing in advance: the decision to open an account always rests with the bank.

How this article was prepared

The article is based on the consolidated text of Council Regulation (EU) 833/2014 as of 24 July 2026 (Articles 1, 5b, 5c, 5d, 5e, 5f, 5g and 12), Council Regulation (EU) 2025/2033 of 23 October 2025 (the 19th sanctions package), the European Commission's consolidated FAQ on sanctions against Russia as of 23 October 2026 (sections on deposits, payment services and crypto-assets), Commission Delegated Regulation (EU) 2026/46 of 3 December 2025 adding Russia to the list of high-risk third countries, and Payment Accounts Directive 2014/92/EU. I did not find recent 2026 Commission answers to European Parliament questions on accounts of Russian nationals. Banks' internal rules are not published and are described from our practice. This article is not legal advice on your situation.