Bundesbank [DEU] ¦ FAQ on Financial Sanctions (as of June 2026)

A practical guide to the current sanctions landscape

The Deutsche Bundesbank’s June 2026 FAQ on financial sanctions offers a useful snapshot of how EU sanctions are working in practice, especially in relation to Russia and Belarus. The document is not legislation, but it reflects the Bundesbank’s legal view and operational approach to enforcement. For banks, payment providers, asset managers, and compliance teams, the message is clear: financial sanctions are no longer a narrow screening exercise. They now shape deposits, securities, crypto services, banknotes, central bank reserves, and cross-border payments in a far more detailed way than many institutions still assume.

At the core of the framework are two concepts that drive most of the practical risk – freezing measures and making funds available. The FAQ also shows how heavily the system now depends on ownership, control, beneficial ownership, and the risk of circumvention. That matters because the formal name on an account or contract is not always the end of the analysis.

Financial sanctions are broader than many expect

The Bundesbank defines financial sanctions as restrictions on capital and payment flows. In practice, this includes not only blocking funds of listed persons, companies, and entities, but also limiting financing, investment, certain securities transactions, deposit-taking, and payment services. The FAQ makes clear that EU regulations apply directly in every member state. No national implementing act is needed.

That has an important consequence for market participants. Each person or company is responsible for making sure its own business follows the rules. The burden does not sit only with the authorities. Financial institutions in particular are expected to maintain screening tools, internal controls, and procedures that allow them to detect new listings and freeze relevant accounts and assets without delay.

For the financial crime sector, this is a classic control environment issue. Sanctions compliance is not only about avoiding direct dealings with a listed counterparty. It is also about detecting indirect exposure, hidden control, and transactions that may look routine but can still breach a restriction.

Bastian Schwind-Wagner _Follow

"The Bundesbank’s June 2026 FAQ shows how financial sanctions against Russia and Belarus have become a highly structured compliance regime. The rules now reach far beyond account freezing and list screening, covering deposits, securities, crypto services, payment messaging, and the risk of control through ownership or influence.

For financial institutions and other market participants, the main challenge is not only identifying listed parties, but also understanding indirect exposure and possible circumvention. The result is a compliance environment that demands careful due diligence, strong internal controls, and close attention to the exact structure of each transaction."

Freezing funds now depends heavily on control

One of the most important parts of the June 2026 FAQ is the updated guidance on ownership and control. The Bundesbank refers to a recent Court of Justice of the European Union judgment, EM System, which shapes how control should be assessed. If a listed person holds at least 50% of the shares in an otherwise unlisted company, there is a rebuttable presumption that the company’s funds are controlled by the listed person. Until that presumption is rebutted, the funds should be treated as frozen.

The FAQ also makes clear that control is not limited to formal ownership. A listed person may control assets through legal rights, such as a power of attorney, or through direct or indirect decisive influence. In other words, a company can be affected by sanctions even if it is not itself named on a sanctions list.

This is a major issue for compliance teams dealing with ownership structures, family-owned businesses, and entities in third countries. The Bundesbank’s view is that control can arise from a combination of legal rights, economic dependence, and personal proximity. That means due diligence must go beyond simple list screening.

Beneficial ownership is relevant, but not automatic

The FAQ also addresses beneficial ownership. A sanctioned beneficial owner behind an unlisted company may affect the sanctions status of that company, but there is no automatic rule that the company itself is always caught. The key question remains whether the company or its assets are controlled by the listed person in the sanctions-law sense.

This matters because AML concepts and sanctions concepts overlap, but they are not identical. In AML, beneficial ownership thresholds often turn on 25%. In sanctions, the analysis is different and more fact-specific. Institutions cannot assume that a person who is relevant under AML rules will necessarily trigger a sanctions freeze, but they also cannot assume the opposite.

Payments to Russia and Belarus are not generally prohibited

The FAQ is careful on one point that is often misunderstood. There is no blanket ban on all payments to Russia or Belarus, and no general ban on accepting all payments from those countries. The restrictions are targeted. They apply to listed persons, specific sectors, specific institutions, and particular types of transactions.

That said, the practical picture is still restrictive. A payment may be legal in theory but blocked in practice because the recipient is listed, controlled by a listed person, or falls within a sectoral prohibition. There are also anti-circumvention rules. So even where a transaction is not directly prohibited, institutions must still ask whether it is being used to route value to a sanctioned party.

Deposit restrictions create a separate compliance risk

The FAQ devotes a long section to deposit bans. For Russia, EU credit institutions may not accept deposits from Russian nationals or Russia-based natural persons, or from Russia-based legal entities, where the total value per institution exceeds \u20ac100,000. Similar rules apply for Belarus, with some differences.

The key compliance point is aggregation. The balance of all accounts held by the same customer at the same institution must be added together. Joint accounts also count, and the rule can catch situations where the economic exposure is spread across multiple accounts. The FAQ gives examples showing that account holders, not mere attorneys-in-fact, are the main focus. Still, powers of attorney can raise circumvention concerns.

Existing deposits above the threshold receive a grandfathering treatment. The customer may keep the money and use it, but the balance cannot be increased. Transfers between accounts can be allowed in some cases, but only if they do not amount to a fresh acceptance of a deposit or create a new creditor relationship. Cash movements are often more problematic than book transfers.

For banks, this is a good example of how sanctions controls and deposit product design intersect. A transaction can be harmless from a customer-service perspective but still trigger a breach if it changes the legal structure of the funds.

Securities restrictions remain extensive

The securities section of the FAQ confirms that the EU restrictions on Russian and Belarusian securities are still broad and technical. Certain transferable securities and money-market instruments issued by designated Russian or Belarusian entities cannot be bought, sold, or handled through related services if the issue date or maturity conditions fall within the scope of the relevant articles.

The Bundesbank’s view is that these bans are investor-focused and apply regardless of whether the purchase happens on the primary or secondary market. That means market participants cannot avoid the restriction simply because a security was acquired from another investor rather than from the issuer.

The FAQ also addresses American Depositary Receipts and Global Depositary Receipts. These instruments may fall within the securities restrictions depending on their structure and the underlying shares. Even where the securities ban does not apply directly, they may still be treated as funds subject to freezing rules if owned or controlled by a sanctioned person.

Crypto and payment services are now directly in scope

The June 2026 FAQ reflects the tightening of the EU sanctions framework around crypto and payment services. Under the current Russia regime, the provision of crypto services, specified payment services, and e-money issuance for Russian nationals, Russia-based natural persons, and Russia-based legal entities is prohibited, subject to legal exceptions and licensing routes.

The document also notes newer transaction bans involving Russian crypto-asset service providers and platforms that enable transfers or exchanges of crypto assets. Belarus has its own equivalent restrictions.

For financial crime teams, this is significant because sanctions risk now extends well beyond traditional banking rails. Crypto service providers, custodians, payment intermediaries, and firms that facilitate value transfer must treat sanctions screening as a core control, not an add-on.

SWIFT is no longer the only messaging issue

The FAQ explains that the former “SWIFT exclusion” has been expanded into broader transaction bans for certain entities. It also states that it is prohibited for EU-based persons and entities operating outside Russia to connect to Russia’s SPFS system and certain equivalent Russian payment messaging systems. This includes SBP and Mir.

That means the sanctions perimeter now includes infrastructure. It is not just about who is paid, but also about what systems are used to process or support the payment.

Banknotes, central bank reserves, and public funding

The Bundesbank FAQ also covers several other areas that are often overlooked in sanctions reviews. Euro banknotes and banknotes of other EU member state currencies may not be sold, delivered, transported, or exported to Russia or Belarus, subject to limited exceptions such as personal travel use.

The document also confirms that transactions involving reserves and assets of the Russian and Belarusian central banks are prohibited, again with exceptions aimed at financial stability. And it clarifies that certain public support measures cannot be granted to designated entities, with the restriction aimed at public-sector assistance rather than private support.

These points matter because sanctions compliance increasingly touches treasury operations, cash handling, public finance, and even government-backed programs.

The enforcement model is built on reporting and cooperation

Another message from the FAQ is that enforcement is not passive. Banks and crypto custodians are expected to report frozen assets and cooperate with the Bundesbank. The Bundesbank actively requests information through circulars, checks compliance through on-site inspections, and receives notifications about frozen accounts. It does not, however, disclose those reports to third parties.

The FAQ also highlights the role of the Central Office for Sanctions Enforcement andthe Federal Office for Economic Affairs and Export Control, depending on the type of measure involved. Financial sanctions are only one part of the wider German and EU sanctions architecture.

What financial crime teams should take from this

The June 2026 Bundesbank FAQ shows that sanctions compliance is increasingly a matter of structure, control, and indirect exposure. A simple list-screening exercise is no longer enough. Institutions need to understand ownership chains, control rights, deposit aggregation, payment routing, securities issuance dates, and the risk of circumvention.

For financial crime professionals, the practical lesson is clear. Sanctions controls now sit at the intersection of AML, payments, securities, treasury, crypto, and trade finance. The most effective programmes will be those that treat sanctions as a dynamic risk discipline, not a static legal check.

Dive deeper

• Deutsche Bundesbank ¦ Häufig gestellte Fragen zum Thema Finanzsanktionen ¦ Link