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.