By Елена Казакова

Deadline for EU citizens and EU companies to close the accounts in sanctioned Russian banks – August 26, 2023

ROSBANK, formerly part of the Société Générale Group serving most French companies doing
business in Russia and their subsidiaries, as well as French citizens residing in Russia, was added to
the EU sanctions list on February 25, 2023 as a result of the adoption of the 10th package of
sanctions EU (Annex I to Council Regulation (EU) No 269/2014).
Two other major Russian banks, Tinkoff and Alfa-Bank were also included in the sanctions list.
Inclusion in the EU sanctions list means freezing the assets of these banks located in the EU, as well
as their disconnection from the SWIFT system.
The inclusion of Rosbank, Alfa Bank and Tinkoff Bank in the EU sanctions list entails an
obligation for residents of the EU (individuals and legal entities), as well as Russian legal entities
under their control, to close their accounts with these banks no later than August 26, 2023.

The funds remaining on the accounts may be transferred to other Russian, non-sanctioned, or
foreign banks. However, such transfer is per se prohibited by the EU regulations as an operation
involving the sanctioned bank. In order to conduct it, the owner of account shall obtain an
authorization from the regulator of the relevant EU Member State.

«The competent authorities of a Member State may authorize the release of certain frozen funds or
economic resources belonging to the entities listed under entry numbers 198, 199 and 200 under the
heading ‘Entities’ in Annex I, or the making available of certain funds or economic resources to
those entities, under such conditions as the competent authorities deem appropriate and after having
determined that such funds or economic resources are necessary for the termination by 26 August
2023 of operations, contracts, or other agreements, including correspondent banking relations,
concluded with those entities before 25 February 2023».
As far as the French residents are concerned, the request for approval of the transfer of funds shall be
filed with the General Directorate of the Treasury at https://sanctionsfinancieres.dgtresor.gouv.fr.
Taking into account the deadline of August 26, 2023, we strongly recommend you to make a request
for transfer to the authority without further delay.
HÉRÈS will be happy to assist you in filling out and sending the application.


Do not hesitate to contact us, our lawyers will reply as soon as possible.

Contact us