TITLE: European Union Updates Sanctions Guidance on Payment Services and Crypto-Asset Restrictions for Russian Nationals and Entities BODY: On 13 March 2026, the European Commission published frequently asked questions clarifying the application of Article 5b(2) of Council Regulation (EU) No 833/2014, as amended by Regulation (EU) 2025/2033 (the 19th sanctions package). Article 5b(2) prohibits the provision of specific payment services, e-money services, and crypto-asset services to Russian nationals, natural persons residing in Russia, and legal persons, entities or bodies established in Russia. The prohibited services include: issuing payment instruments; acquiring payment transactions; providing payment initiation services; and issuing electronic money. The prohibitions do not apply to nationals of European Union member states, European Economic Area countries, Switzerland, or natural persons with temporary or permanent residence permits in these jurisdictions. The guidance clarifies that the prohibitions apply to both new and existing customers. Payment service providers (PSPs) are not required to close existing accounts or terminate contracts, but must immediately discontinue prohibited services for customers falling within scope. The measure does not prohibit the continued use of existing payment instruments such as debit or credit cards, nor does it restrict direct bank transfers, cash withdrawals, or access to online or mobile banking services. However, issuing new payment instruments—including renewal or replacement of existing instruments—to Russian nationals or residents is prohibited, including additional cards and commercial cards personalised for such individuals. Primary responsibility for sanctions compliance regarding account-servicing lies with account-servicing payment service providers (ASPSPs). Payment initiation service providers (PISPs) are not required to conduct full screening of individual payment transactions. All PSPs must take reasonable steps to identify and mitigate circumvention risks, including indirect provision through intermediaries or contractual arrangements designed to circumvent sanctions.

CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]

Horizon Scanning Outline. Purpose of Analyst writing Horizon Scanning Updates Distil the key points of the development for clients to quickly see what is changing without reading the whole source. Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes. Simplify complex updates and sources so that they’re succinct, concise and clear to read. Consistently structure and write updates in the same format. Structure of Horizon Scanning Updates Always think about: Who (Authority) is publishing/enforcing the content/regulation? Where (Jurisdiction)? What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed? Who is this update applicable to (credit, e-money institutions, etc.)? Why is this update noteworthy? What is its significance? When is the update applicable? Title Describe what the update is about. Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what). All titles should be written in present tense. Avoid using acronyms Approx 10 - 20 words Example Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance Paragraph 1 Open with the date of the update (When) Name the authority that released the update (Who) Summarise the release (What) Example On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets. Paragraph 2 Summarise key points. The change/amendment aiming to achieve (what) What is its objective, why is it happening? Why is it significant? (why) Who does it impact or concern? (Who) The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document. Example SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to: Study Indian and global best practices. Prepare the guidelines. Address the concerns and issues arising from AI/ML usage. SEBI is consulting on the following principles to develop the guidelines: Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models. Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information. Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results. Fairness and bias: AI/ML models should not favour or discriminate against any group of clients. Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security. Paragraph 3 Acts as a “Call To Action”. Provide forward looking context: What actions need to be taken? Who needs to take action? Next steps to the development. Include any relevant dates (When) Response dates - should always be provided for consultations Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted. Example The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026. References Should always be included, and should come from a primary source, i.e., an authority, not a news source. General Style Notes: 200-250 words Active voice Authorities and companies referenced as a single entity (“It”, not “they”) Titles in title case Internal Vixio vocabulary guide Content Style Guide Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content. A Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA). Act - when just referring to “the act”, it does not need a capital a. Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell). - advice (noun) - give formal suggestions (for example, I gave them advice). Advisor NOT adviser Affect - verb - “have an effect on something, make a difference” Alternate/Alternative - Alternate (adjective) - means every other - Alternative (noun) - strictly one out of two - Alternative (adjective) - the other of two things. Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”. AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT Among/while NOT Amongst/whilst API - application programming interface Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act. Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”. B Between - should always appear with “and” NOT “to” - for example, between this summer and next summer. Big tech - two words, breaks convention of other tech words Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522). Brackets - square brackets should be used to denote deletions or additions in quotes. Buy now, pay later - no hyphens Bullet points - see Lists C Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a) Cardrooms not card rooms Cases - legal cases should appear in italics, with a v for versus. Casino-resorts NOT casino resorts or resort-casinos Chief executive NOT chief executive officer Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes) Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000) Comparisons - compare with (highlighting differences) - compare to (highlighting similarities) Companies/organisations - singular entities (it NOT they) should be followed by “which/that” rather than “who” Ltd, not Limited Complement - to accompany something/add value Compliment - give praise (complimentary = free) Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings) Comprise/comprising - should NOT be followed with “of”, as it means to “consist of” Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,) Continually - if something occurs repeatedly/regularly in the same way Continuously - if something occurs without interruption or gaps Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone) Contrast - by contrast - when comparing one thing to another - in contrast - simply noting a difference Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting Court of Justice of the European Union (CJEU) rather than ECJ Cryptocurrency - one word, not hyphenated. Crypto-assets - hyphenated Cybersecurity - one word, not hyphenated CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar) m for million, bn for billion, trn for trillion. D Date format - Month, Day, Year (e.g., March 7, 2019) For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…” For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...” For NIBs: always use dates rather than days. Department for Digital, Culture, Media & Sport - ampersand Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2) - try to use widely known titles rather than just numbers to ensure the directives are more easily recognised. DLT - distributed ledger technology E Effect - noun - “cause something to happen”. Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–). Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”. esports NOT eSports or e-sports Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”. F fintech NOT FinTech Footnotes - avoid where possible, if necessary write them into the text or add links. G GGR - “gross gaming revenues” Government - does not need a capital g. Governor - should be written out in full, NOT Gov. Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines) H Headlines - all words should begin with a capital Horseracing NOT horse racing Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money - DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper I Impact - should be used as a noun - i.e. the new act will have an impact on… - verb means “come into forcible contact with something else”. - using “affect” as a verb is more accurate. J Judgment - legal decision Judgement - one’s own opinion Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters. Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive. OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur DON’T need capitals unless a figure of importance (i.e., Prime Minister, President) Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be. Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team). K KYC - know your customer L Legislature - does not need a capital l. Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables. Licence - noun (UK), i.e. a driver’s licence License - verb/noun (US) Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent). M MONEYVAL NOT Moneyval More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players. N Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive. Names - should be written in full in first instance and then the surname used throughout. Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences. Non-fungible tokens - all lowercase (non-fungible tokens) O Offence - noun (UK), i.e. commit an offence Offense - noun (US) Organisations/companies - singular entities (it NOT they) should be followed by “which/that” rather than “who” Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears). Over - should not be used as a replacement for “more than”. P Parliament - does not need a capital p. Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”. - passed is the past tense of “to pass” - “the law was passed in government”. Prepaid, not pre-paid Percentages - numbers should always be written as figures percent NOT per cent or % Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent) Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to” Principal - main, most important Principle - a fundamental source or basis of something Programme (UK) Program (US, UK - for computer program, Australian English) Q Quotes - speaker should be referenced in the past tense (said NOT says) Quote marks - double quote marks should be used for speech - single quote marks should only be used for titles and within quotes. (See Quote reference sheet for more information on how to use quotes.) R regtech NOT RegTech Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines) Racetracks not race tracks S Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018. Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act. Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.) Sports betting NOT sportsbetting Sports team names Storey (pl. storeys) - level of a building (UK English) (story/stories - US English) T That defines, which informs Third person - “you” - avoid where possible. Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a) Tenses - content should generally be written in past tense - present tense should be used for something that has just happened and will be continuing into the future. U United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”) U.S. Department of Justice - Justice Department (with capitals as requested) V Vixio GamblingCompliance / Vixio PaymentsCompliance Vixio (to be used on its own after first instance) W Which informs, that defines While/among NOT Whilst/amongst While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”. X Y Year quarters - Q1, Q2, H1, H2, etc. Z Acronyms AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT API - application programming interface DLT - distributed ledger technology --- Now, given the above instructions and style guide, please generate a horizon scanning update based on the following webpage content. Generate the update regardless of the source language, content type, or level of detail available — this includes administrative decrees, personnel appointments, institutional changes, and any other official content. Use whatever information is present. PROVISION OF PAYMENT SERVICES RELATED PROVISION: ARTICLE 5b(2) OF COUNCIL REGULATION 833/2014 FREQUENTLY ASKED QUESTIONS – AS OF 13 MARCH 2026 1. What services are prohibited by Article 5b(2) of Regulation (EU) No 833/2014, and who is affected? Last update: 13 March 2026 Article 5b(2), as amended by Regulation (EU) 2025/2033 (part of the 19th sanctions package), prohibits the provision of crypto-asset services and certain payment and e-money services to Russian nationals, natural persons residing in Russia and legal persons, entities or bodies established in Russia. The prohibitions are limited to the specific services listed in points (a), (b) and (c): • crypto-asset services (point (a)) For details on measures concerning crypto-assets, please check the dedicated FAQ; • the issuing of payment instruments, acquiring of payment transactions, and provision of payment initiation services (point (b)) In Article 4 of Directive (EU) 2015/2366 (PSD2), the services under point (b) are defined as follows, respectively: “(45) ‘issuing of payment instruments’ means a payment service by a payment service provider contracting to provide a payer with a payment instrument to initiate and process the payer’s payment transactions;” “(44) ‘acquiring of payment transactions’ means a payment service provided by a payment service provider contracting with a payee to accept and process payment transactions, which results in a transfer of funds to the payee;” “(15) ‘payment initiation service’ means a service to initiate a payment order at the request of the payment service user with respect to a payment account held at another payment service provider;” • the issuing of electronic money (point (c)) In Article 2 of Directive 2009/110/EC (EMD2), electronic money is defined as follows: “2. ‘electronic money’ means electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds for the purpose of making payment transactions as defined in point 5 of Article 4 of Directive 2007/64/EC, and which is accepted by a natural or legal person other than the electronic money issuer;” 2. Who is exempted from Article 5b(2)? Last update: 13 March 2026 According to Article 5b(3), the prohibitions in Article 5b(2) do not apply to: • nationals of Member States, EEA countries or Switzerland; • natural persons with a temporary or permanent residence permit in the EU, EEA or Switzerland. Holders of long-stay Type D visas who have completed the registration formalities in the place where they reside are typically considered legally resident under national residence rules and are thus covered by the exemption in Article 5b(3). Examples include long-stay visas for student, employment, humanitarian and family reunification purposes, depending on national law. 3. Do the prohibitions in Article 5b(2) cover non-Russian entities owned or controlled by Russian persons? Last update: 13 March 2026 No, the prohibitions cover Russian nationals, natural persons residing in Russia and legal persons established in Russia. Services may continue to be provided to entities legally established in the EU or third countries, even if they are owned or controlled by Russian persons, unless these are being used as a conduit to circumvent sanctions. See also Question 4. 4. What constitutes indirect provision of services under Article 5b(2)? Last update: 13 March 2026 Indirect provision may occur when a prohibited service is channelled through intermediaries, third-country entities or contractual arrangements designed to circumvent sanctions. All sanctions prohibitions must be read in conjunction with Article 12 of Regulation (EU) No 833/2014, which prohibits to participate knowingly and intentionally in activities the object or effect of which is to circumvent prohibitions in the Regulation. Financial institutions should take reasonable steps to identify and mitigate circumvention risks. 5. Does Article 5b(2) require payment service providers (PSPs) to close accounts or terminate existing contracts with Russian or Russia-based clients? What happens when a client enters the scope (e.g. a Russian national who is no longer legally resident in the EU)? Last update: 13 March 2026 No, Article 5b(2) does not require EU operators to close accounts or terminate existing contractual relationships. PSPs may maintain existing accounts and continue offering non- prohibited services. However, the prohibitions in Article 5b(2) apply to both new and existing customers. PSPs must therefore immediately discontinue the specific services prohibited under Article 5b(2) for any customer who falls within scope, including those who were already customers before the measure entered into force or who subsequently become in scope (for example, when a Russian national ceases to be legally resident in the EU; in this scenario, PSPs must act as soon as they become aware of the change in the customer’s status). This applies both to new contracts and to the continued provision of prohibited services under existing contracts. 6. What sanctions-compliance responsibilities do payment service providers (PSPs) have under Article 5b(2)? Last update: 13 March 2026 All PSPs are responsible for ensuring that they do not provide the prohibited services to persons falling within the scope of Article 5b(2). With regard to the execution of payment transactions, according to recital 19 of Regulation (EU) 2025/2033, primary responsibility for sanctions compliance with regard to contracts related to prohibited services lies with the account-servicing payment service provider (ASPSP). Payment initiation service providers (PISPs) are not expected to carry out full screening of individual payment transactions at the moment of executing the initiation. The obligation under Article 5b(2) for both PISPs and acquirers of payment transactions is limited to ensuring that they do not provide the prohibited services. This is without prejudice to other compliance responsibilities PSPs may have under other EU sanction regulations. 7. Does the prohibition in Article 5b(2)(b) cover the use or servicing of existing payment instruments such as debit cards, credit cards or payment cards via e- wallets? Last update: 13 March 2026 No, the measure does not prohibit the continued use of, or provision of non-prohibited services for, existing payment instruments (e.g. cards). EU operators are not required to cancel or freeze existing payment instruments. Article 5b(2)(b) concerns the issuing of new payment instruments to Russian nationals or natural persons residing in Russia, or to legal persons, entities or bodies established in Russia. This includes the renewal or re-issuing of existing payment instruments (i.e. issued before entry into force). If the execution of a payment transaction using such an instrument requires a service that is itself prohibited (e.g. acquiring of payment transactions), then the transaction should be blocked, not because the instrument is invalid, but because the underlying service enabling it is prohibited. For instance, transactions processed via digital wallets or tokenised platforms typically involve acquiring services. In that context, the prohibition is on the acquirer. 8. When a new payment instrument is issued under the exception referred to in 5b(3), must a customer’s residence permit be valid for the entire validity period of the instrument, or is it sufficient for the residence permit to be valid on the day the new instrument is issued? Last update: 13 March 2026 The residence permit must be valid for the entire validity of the instrument. 9. Does Article 5b(2)(b) prohibit access to online or mobile banking services? Last update: 13 March 2026 No, Article 5c(1a) of Regulation 833/2014 contains an exemption for the provision of personalised security credentials necessary to access an existing account. Access to online or mobile banking can therefore continue. 10. Does Article 5b(2)(b) prohibit direct bank transfers and cash withdrawals? Last update: 13 March 2026 No, Article 5b(2)(b) targets specific payment services (issuing instruments, acquiring, initiating), not all payments services as defined in Article 1, point (zi) of Regulation (EU) 833/2014. Prohibited payment services are specifically those referred to in points 5 and 7 of Annex I to Directive (EU) 2015/2366 (PSD2), not other payment services listed under that Annex. This is without prejudice to other compliance responsibilities PSPs may have under other EU sanction regulations. 11. Does Article 5b(2)(b) prohibit issuing additional cards in the name of Russian nationals or residents (e.g. family members or employees)? Last update: 13 March 2026 Yes, the prohibition on the issuing of payment instruments covers any natural person in whose name a payment card is issued, even if that natural person is an additional cardholder and not the primary account holder. Therefore, if the additional card is issued in the name of a Russian national or a natural person residing in Russia, its issuance (including renewal or replacement) is prohibited under Article 5b(2)(b), regardless of whether the underlying account holder is an EU- based individual or company. The provision of non-prohibited services through an existing additional card is not prohibited. Where relevant, derogations in Article 5c may apply, for example for basic needs. 12. Does Article 5b(2)(b) prohibit issuing commercial cards personalised for Russian nationals or residents? Last update: 13 March 2026 Yes, Article 5b(2)(b) prohibits the issuing (including renewal or replacement) of a payment instrument to, or personalised for, any natural person who falls within scope, even if the underlying contract is with a legal person established in the EU. The provision of non-prohibited services through an existing commercial card is not prohibited. ‘Commercial card’ means any card-based payment instrument issued to undertakings or public sector entities or self-employed natural persons which is limited in use for business expenses where the payments made with such cards are charged directly to the account of the undertaking or public sector entity or self-employed natural person. Where relevant, derogations in Article 5c may apply, notably those for legitimate cross-border trade and the exclusive use of subsidiaries in Russia. 13. Is redirection of a user to their own bank’s interface to initiate a payment (so called ‘bank-link’) prohibited under Article 5b(2)(b)? Last update: 13 March 2026 The redirection of a user to their own bank’s interface to initiate a payment is not considered a payment initiation service under Article 4(15) of Directive 2015/2366 (PSD2), provided that: - the user is redirected to their own bank’s secure interface without third party participation; - the user initiates the payment directly within their bank; - no third-party PSP (e.g. licensed PISP) initiates the payment on behalf of the user. However, if a third-party PSP initiates the payment (e.g. via open banking APIs), this does qualify as a payment initiation service and is prohibited when provided to Russian nationals, residents or entities falling under Article 5b(2). As regards obligations of PISPs and ASPSPs in this context, please see answer to question 6.

Frequently asked questions on the provision of payments services concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it

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