top of page
  • FAI Comply

European Council Decision 2022/346 -restrictive measures in view of Russia’s actions

In regards of the latest announcement in regards to the EUROPEAN COUNCIL DECISION (CFSP) 2022/346 published in the official journal of the European Union on the 2nd of March:

In view of the gravity of the situation, and in response to Russia’s military aggression against Ukraine, it is appropriate to introduce further restrictive measures with regard to the provision of specialised financial messaging services in simplified terms SWIFT to certain Russian credit institutions and their Russian subsidiaries.

The Institutions targeted are:

  • Bank Otkritie

  • Novikombank

  • Promsvyazbank

  • Bank Rossiya

  • Sovcombank



Why are these Russian credit institutions targeted? These Institutions which are relevant for the Russian financial system are already the subject of restrictive measures imposed by the Union or by partner countries and, subject to certain exceptions, with regard to engagement with the Russian Direct Investment Fund. It is also appropriate to prohibit, subject to certain exceptions, the supply of euro denominated banknotes to Russia. The following measures are mentioned: 1) It shall be prohibited as of 12 March 2022 to provide specialised financial messaging services in simplified terms SWIFT, which are used to exchange financial data, to:

  • the legal persons, entities or bodies listed in the list of institutions listed above.

  • to any legal person, entity or body established in Russia whose proprietary rights are directly or indirectly owned for more than 50 % by an entity listed above.

2) It shall be prohibited to sell, supply, transfer or export 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.

3) In regards to Point 2, this measure shall not apply to the sale, supply, transfer or export of euro denominated banknotes provided that such sale, supply, transfer or export is necessary for:

  • the personal use of natural persons travelling to Russia or members of their immediate families travelling with them; or

  • the official purposes of diplomatic missions, consular posts or international organisations in Russia enjoying immunities in accordance with international law;

4) It shall be prohibited to invest, participate or otherwise contribute to projects co-financed by the Russian Direct Investment Fund (in relation to any entity listed above). 5) On another hand the competent authorities in the EU may authorize, under such conditions as they deem appropriate , an investment participation in, or contribution to, projects co-financed by the Russian Direct Investment Fund after having determined that such an investment participation or contribution is due under contracts concluded before 2 March 2022 ancillary contracts necessary for the execution of such contracts.

If you have questions or need further advice please do not hesitate to contact us to discuss how we can help you.


Written by Angeliki Georgiou, Legal Consultant of Financial Associates International -

FAI Comply


bottom of page