Russians with EU residence permits may violate sanctions without knowing about it

Russians with residence permits from EU countries violate EU sanctions if they deposit funds in sanctioned Russian banks. This follows from the response of the State Security Service (Valsts drošības dienests, VDD) media SanctionsLists.org (telegram-channel @finalsanction).

The background of SanctionsLists.org request is as follows: on February 2, 2026, VDD appealed to the prosecutor’s office with a request to open a criminal case against a Latvian citizen who worked as a programmer for a Russian company and for several months he received wages to the bank account of the Russian Alfa-Bank, which is under sanctions.

SanctionsLists sent a request to VDD to find out whether such a violation applies only to EU citizens or may also affect Russians with a residence permit, because it is likely that some Russians in Latvia and other EU countries continue to work remotely for Russian customers, receiving money on the cards of sub-sanctioned banks: Sber, Alfa-Bank, VTB, Bank Saint Petersburg and dozens of others.

We provide our readers with the full VDD answer:

“Please be informed that in the assessment of Latvian State Security Service (VDD) in this case the person violated the EU sanctions in two ways:

1) by providing programming services to a company in Russia, something that residents of the EU Member States are prohibited from doing (Article 5n of Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine);

2) by directly making available funds to a legal person included in the EU sanctions lists – in this case, the salary transferred to the account of a bank subject to the EU sanctions.

As already mentioned in our press release, residents of the EU Member States are prohibited from directly or indirectly making available funds and economic resources to natural and legal persons included in the EU sanctions lists (Article 2 of Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine).

Since 25 February 2023, “Alfa-Bank JSC” is included in Annex I of Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

Regarding your second question, we can confirm that making available funds to any bank included in the EU sanctions lists is considered a violation of sanctions imposed by the EU if committed by any EU resident – including a Russian citizen with a residence permit issued by one of the EU countries.”

SanctionsLists notes that there are still banks in Russia that are not under EU sanctions. Given the risks of violating sanctions, it is better for Russians with residence permits from European countries to transfer their funds to such banks or withdraw them completely.

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