The €100,000 limit for Russian citizens in EU banks: who it applies to and which status lifts it

The €100,000 limit for Russian citizens in EU banks: who it applies to and which status lifts it

The €100,000 limit is not a ban on holding an account in the European Union and not a freeze on money. It is a ban on the bank accepting new deposits above the threshold, and it is lifted by a status, not by the choice of bank.
Below — the text of the rule, whom it does not apply to, how the bank counts it and why this threshold is the first question when buying an apartment.

What exactly does the €100,000 limit prohibit, and for whom?

It prohibits the bank from accepting deposits if the client's total deposits in that credit institution would exceed €100,000. The client here is a Russian citizen or a person living in Russia, regardless of where the account is opened.

The rule is Article 5b(1) of Regulation 833/2014: accepting deposits from Russian citizens and residents above €100,000 per credit institution is prohibited. The ban is addressed to the bank, not the client: the bank must not credit an incoming payment that raises the balance above the threshold, and must report deposits above it to the competent authority of its country.

The rule has applied since February 26, 2022 and only to new deposits: money that was in the bank before that date can stay, but the balance cannot be increased above the threshold. The client is free to dispose of the funds — withdraw, transfer, hold.

Whom does the limit not apply to, and which status lifts it?

Citizens of EU, EEA countries and Switzerland, and holders of a residence permit in one of these countries — temporary or permanent. This exception is written into the same article of the regulation, and its wording is checked as of the publication date.

The practical consequence: the limit is lifted not by a second passport or an address abroad but by a status document. A valid residence permit lifts the rule entirely — on all accounts and in all banks of the Union. If the permit has expired or been revoked, the exception ends from that same date: the bank is not obliged to freeze or reduce the balance above the threshold, but it no longer accepts new credits above it.

A separate category is deposits required for non-prohibited cross-border trade in goods and services between the Union and Russia: they do not fall under the limit. This exception does not apply to an individual buying an apartment.

How does the bank count the limit: per account, per person or per family?

Per person and per credit institution. The threshold is the sum of all the client's balances in that bank: current accounts, deposits, accounts in different currencies, a sole proprietor's account. Splitting across accounts changes nothing: all of a client's balances in one bank are added together.

The rule does not treat the family as a unit: for spouses who are each Russian citizens without a status, the threshold is counted separately for each. The bank considers a joint account under its own rules for attributing the balance, and practice varies here — this is a question for the specific bank, not for the regulation.

The threshold also includes money that came in for the apartment purchase. The deal goes through a notary, but the funds for it go through the buyer's account, and at the moment they are credited they are a deposit within the meaning of the regulation.

What happens if the limit is exceeded, and how does it relate to buying an apartment?

The bank does not credit an incoming payment above the threshold: the transfer is returned to the sender, and the compliance department is entitled to ask questions about the source of funds and restrict operations on the account until it gets an answer. The regulation does not require a freeze, but the bank works under its own risk policy, and that is stricter than the rule.

The asset jurisdiction in which Alliance handles the deal is Romania. A property of about €100,000 with notary fees and tax sits right at the threshold, and the money arrives in the buyer's account at BRD or BCR, which is opened from a week. Next to the limit there is a second rule — the payment restrictions under Article 5b(2) as amended by Regulation 2025/2033; they close off cards and some payment operations and are covered on a separate page of the cluster.

Hence the order: status first. The structure is not built on keeping the balance below the threshold — it is built on a status that lifts the rule entirely. Without a status an account can be opened, but a purchase through it runs into the limit and the payment restrictions at the same time.

What to do if you deposited more than the limit without a status and the account is blocked?

Recover through the status and documents, not through a second bank. A second bank will see the same citizenship and ask the same questions; the first one has already asked them in writing, and they need to be answered.

A four-step sequence.

First — the assessment: what exactly happened, a credit above the threshold or a restriction over the source of funds; these are different grounds, and the letters to the bank about them are different.

Second — documentation: the chain of the money's origin from the source to the incoming payment — contracts, tax returns, statements.

Third — the status route: a residence permit document lifts the limit from the date of issue, and the bank is notified of it in writing.

Fourth — correspondence with the bank only through written requests via the official channel: every answer from the bank becomes a document, and a phone call does not.

What does not work in this sequence: trying to explain the credit verbally, transferring the balance to another bank before answering the request, and waiting for the restriction to lift by itself.

How does Alliance take a client through the limit?

As a procedure with a named law and a named authority: Article 5b(1) of Regulation 833/2014, supervision by the competent authority of the bank's country; in Romania the bank, the notary and the lawyer are reporting entities working 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 with an individual.
An office in Constanța, licenses 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 the status is attainable: by which route and within what time the limit stops applying.
The second covers the source of funds: which documents the bank will accept for your amount.
The result is a route built out with the sequence, timelines and budget, or a reasoned refusal explaining why.
Personal sanctions are an absolute boundary.

The working order is strict: status first, then money, then the asset. The apartment comes third in this sequence, and its price is discussed only after the first two steps are closed.

Where to start if the money is already in the European Union or soon will be?

With two figures: the total balance in each bank where you have an account, and the amount that has to come in for the deal.
If the second plus the first is above the threshold and you have no status, you need to start not with the property but with the status route — and not a month before the deal.

Alliance carries out a free compliance assessment with a written opinion.
The first section of the opinion covers whether the status is attainable. And a straight answer: whether this structure suits you.
The assessment is free, commits you to nothing and may end in a reasoned refusal explaining why.

Does a temporary residence permit also lift the limit?

Yes. The exception is worded for holders of a temporary or permanent residence permit in an EU or EEA country or Switzerland. There is one condition — the document must be valid: when it expires, the exception ends.

Is the limit counted per person or per family?

Per person and per credit institution. Each family member without a status has their own threshold; the bank attributes joint accounts under its own rules, and this is clarified with it in writing.

An account in another EU country — is the limit counted separately?

The rule is written "per credit institution", meaning it counts balances in each bank separately. This is a description of the rule, not a route: any bank in the Union sees the same citizenship and asks the same questions about the source of funds, and only a status lifts the threshold in all banks at once.