Payment restrictions on a Russian passport in the European Union: what lifts them

Payment restrictions on a Russian passport in the European Union: what lifts them

The restrictions on a Russian passport are lifted by status in the European Union — a residence permit or citizenship of a Union country. Neither choosing a bank, nor a second passport from a third country, nor an account opened earlier does that.
Below: what exactly is prohibited, word for word under the rule, what the ban does not cover, whom it does not apply to, and what to do if a payment for a transaction has already been rejected.

What payment restrictions apply to Russian citizens in the European Union?

Not all payment services, but three named categories. Article 5b(2) of Regulation 833/2014 as amended by Regulation 2025/2033 prohibits providing the following to Russian nationals, persons residing in Russia and legal entities established in Russia: crypto-asset services; issuance of payment instruments together with acquiring of payment transactions and payment initiation services; issuance of electronic money.

The ban is addressed to the service provider and applies regardless of where the client is located: citizenship here is a criterion in its own right. It applies to both new and existing clients.

What is not on the list: an ordinary bank transfer and a requirement to close accounts already opened — the European Commission's guidance of March 13, 2026 states directly that the regulation does not require ending an existing client relationship. We close off the tempting conclusion right away: a narrow list does not mean the payment will go through. Alongside it there is the deposit threshold and the bank's own risk policy, and that policy is stricter than the rule.

Who is exempt from these restrictions?

Citizens of Union countries, the European Economic Area and Switzerland, and holders of a residence permit in one of these countries — temporary or permanent. The exemption is set out in Article 5b(3) of the same regulation.

The European Commission's guidance of March 13, 2026 adds something important: holders of a long-stay category D visa who have completed the residence registration formalities are, as a rule, considered lawfully resident under national rules and fall under the same exemption.

Hence the direct answer to the article's main question: the restriction is lifted by status — a document, not an intention to move and not a second passport from a state outside the Union. The status jurisdiction in which Alliance runs the route is Spain: a permit for international remote work for those whose income comes from a foreign employer or clients.

What does this mean in practice when you buy an apartment?

The transaction takes place at a notary, but the money goes through an account — and that is where the restrictions begin. The direct ban covers cards, acquiring, payment initiation and electronic money; a payment for a transaction runs up not against these, but against the deposit threshold and the bank's willingness to carry out the operation for a client with a Russian passport.

Hence the order, which does not change in our work: status first, money second, the asset third. Status lifts the rules, the account is opened after the status, and the property is reserved when the money can get there. The reverse sequence — a deposit first, then the bank — is the cause of most failed transactions.

If the transaction includes installments, they are offered by the apartment's owner, not the developer, and the installment payments go through the same account under the same rules. The asset jurisdiction in which Alliance runs the transaction is Romania; purchase figures are not given in this article — it is about money and status.

Is the ban related to the €100,000 deposit limit?

No, these are two different rules of the same article. Article 5b(1) prohibits accepting deposits above €100,000 per credit institution; Article 5b(2) covers three categories of payment services.
The first limits how much can be held, the second — which instruments can be used.

They are often confused, and a wrong conclusion is drawn from that. We close it off: both rules are lifted by the same exemption under Article 5b(3), that is, by status, not by choosing a bank or a payment instrument. A detailed breakdown of the deposit threshold is a separate page of this cluster and is not repeated here.

Is a Russian citizen prohibited from buying real estate in the European Union?

There is no direct ban. It was proposed during preparation of the sixth package and did not make it into the adopted text: the restrictions concern money in transit, not property rights. A foreigner with a Russian passport is entitled to acquire real estate, and a non-resident's status as owner is no different from that of any other owner.

We name the risk plainly: regulation changes in packages, and this article does not promise what it will look like next. We work under the rule in force on the transaction date and check it before every payment. Personal sanctions are an absolute boundary: we do not take on work with a listed person in any form.

The account was opened before the status, and a payment for the transaction was rejected — what should you do?

Go back to the order, rather than looking for another bank or trying another country: they will see the same passport there and ask the same questions. There is one sequence — assessment, the status route, then the payment.

In parallel, send the bank a written request about the reason for the refusal. This is not a formality: the European Commission's guidance states directly that Russian citizenship by itself is not a legal ground to refuse a payment. The bank must name the ground — exceeding the deposit threshold, an open question about the source of funds, or its own risk policy.
Whether the situation can be fixed with documents or only with status depends on which ground is named.
Correspondence is conducted in writing: the bank's answer becomes a document, a phone conversation does not.

If a deposit has already been paid, the assessment is urgent — before the next payment is due. The deadline in the contract does not stop while the bank reviews the request, and what is at stake here is not a banking question but money that can be lost.

How does Alliance work, and where should you start?

As a procedure with a named law and a named authority: Article 5b of Regulation 833/2014 as currently amended, with the bank supervised by the competent authority of the bank's country; in Romania, the bank, the notary and the lawyer are reporting entities operating under the rules of ONPCSB, the financial intelligence unit. The company works under a contract that sets out the timelines, the amount and the working procedure; the contract is concluded only with an individual. The office is in Constanța; licenses are publicly available on the website.

The entry point is a free compliance assessment with a written opinion. The first section of the opinion covers whether status is attainable. In total, the opinion answers four questions: whether status is attainable, by which route, which documents are needed for the source of funds, and which bank fits your structure. The result is a built route with a sequence, timelines and a budget, or a reasoned refusal explaining why.

It is worth starting with one check: do you have a document confirming status in the Union as of today. If not, and the money for the purchase is ready, the first step is not choosing a property or opening an account, but the status route. And a straight answer: whether this structure suits you. The assessment is free, does not oblige you to anything and may end in a reasoned refusal explaining why.

Does a residence permit from any Union country lift the restriction, or only one from the country where the account is opened?

Any. The exemption is worded as a residence permit in a country of the Union, the European Economic Area or Switzerland — without being tied to the bank's country. There is one condition: the document is valid, temporary or permanent.

Does the ban apply if you have a second citizenship other than Russian?

Yes, it does. The rule is tied to Russian citizenship, and a passport of a third country does not cancel it. The restriction is lifted only by citizenship of a country of the Union, the European Economic Area or Switzerland, or by a residence permit in one of these countries.

Can you pay for the purchase from a foreign account opened earlier?

The regulation does not require closing an account opened earlier, and the ban under Article 5b(2) concerns not transfers but cards, acquiring, payment initiation and electronic money. But the payment for the transaction still passes through the deposit threshold and the receiving bank's policy. The answer to this question is given not by the age of the account but by whether you have status.