On March 2, 2022 the EU introduced new sanctions entailing, inter alia, the disconnection of certain Russian banks from SWIFT.

As of March 12, 2022, the following banks will be cut-off from SWIFT:

  • Bank Otkritie
  • Novikombank
  • Promsvyazbank
  • Bank Rossiya
  • Sovcombank
  • VNESHECONOMBANK (VEB)
  • VTB BANK

In addition, the new EU Regulation prohibits the sale, supply, transfer or export (“Supply”) of euro denominated banknotes to Russia or to any natural or legal person, entity or body in Russia, including the government and the Central Bank of Russia, or for use in Russia.

However, the Regulation exempts supplies of euro denominated banknotes that are necessary for the personal use of natural persons travelling to Russia or members of their immediate families travelling with them. Furthermore, the supply of euro denominated banknotes that are necessary for the official purposes of diplomatic missions, consular posts or international organisations in Russia, enjoying immunities in accordance with international law, is also exempted.

Finally, the regulation introduces a prohibition on investing, participating or otherwise contributing to projects (“Investments”) co-financed by the Russian Direct Investment Fund. Nevertheless, national authorities may grant licenses for Investments co-financed by the Russian Direct Investment Fund, provided that they are due under contracts concluded before 2 March 2022.

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