Sending money abroad, investing through international platforms or using crypto-related services can involve risks that have little to do with investment performance and everything to do with sanctions compliance. The EU’s 21st sanctions package against Russia and Belarus expands restrictions affecting banks, financial institutions and certain crypto service providers, potentially impacting how some transactions are processed.
For internationally active investors, expatriates and high-net-worth individuals, this is not merely a political development. In practice, sanctions can influence payment processing, verification procedures and access to specific financial services. Understanding where potential issues may arise can help avoid unexpected delays and complications.
Where Problems May Arise
One of the most important changes is the expansion of lists covering banks, financial institutions and crypto-asset service providers with which transactions are prohibited. The sanctions package also adds 48 individuals and 168 legal entities or organisations to asset-freeze measures, meaning that financial resources and economic assets cannot be made available to them directly or indirectly. According to information published regarding the EU’s 21st sanctions package, these additions form a significant part of the latest restrictions.
For most clients, this does not mean they are likely to breach sanctions rules themselves. More commonly, it means that banks, investment platforms and other financial institutions may conduct additional checks on payments, ownership structures or counterparties involved in a transaction.
As a result, a transfer that would normally be processed immediately may require further verification if a bank identifies a possible sanctions connection somewhere within the transaction chain.
Why Crypto Assets Matter Even If You Do Not Own Any
One of the most significant developments concerns crypto-related services.
The sanctions package expands restrictions affecting certain crypto-asset service providers and introduces a new mechanism allowing restrictions on providers and platforms located in third countries if they are used to circumvent sanctions measures. At the time the package was adopted, the relevant list of third-country providers remained empty, but the legal framework has now been established for future action.
This matters even to investors who have never purchased cryptocurrencies. Many financial and technology businesses rely on infrastructure connected to digital asset markets. If a service provider becomes subject to restrictions, additional compliance checks or operational changes may affect related services.
The package also extends restrictions concerning ownership and management participation by certain Russian persons in entities providing crypto-related services. The objective is to reduce opportunities for sanctions circumvention through indirect ownership structures.
What This Means For Your Assets
Most investors will notice little or no change in their daily financial activities. However, some situations may attract greater scrutiny from financial institutions.
Particular attention may arise when dealing with:
- Transfers involving higher-risk jurisdictions
- Lesser-known crypto platforms
- Investments with complex ownership structures
- Transactions involving multiple countries outside the EU
“Financial institutions are usually less concerned with the size of a transaction than with who ultimately stands behind it.”
💡 TIP: Before making a significant international transfer, verify which financial institution or service provider is actually processing the transaction. The brand you see and the legal entity operating behind it are not always the same.
What We Recommend
- Review which institutions handle your significant international transfers.
- Keep records relating to larger international investments and payments.
- Check the ownership and operating structure of lesser-known investment and crypto platforms before using them.
- Expect additional verification requests where cross-border transactions involve complex structures.
FAQ
1. Do the new sanctions only affect Russia and Belarus?
No. Some measures also address entities in third countries where there is a risk that services could be used to circumvent sanctions restrictions.
2. Can ordinary bank transfers be delayed?
Yes. Financial institutions may carry out additional reviews where a transaction requires further sanctions screening or verification.
3. Does the package affect crypto assets?
Yes. The new measures expand restrictions relating to certain crypto-asset service providers and introduce additional mechanisms aimed at preventing sanctions circumvention.
4. Were sanctions lists expanded?
Yes. The package adds 48 individuals and 168 legal entities or organisations to sanctions measures involving asset freezes and restrictions on providing funds or economic resources.
5. Do investors need to change their financial strategy?
In most cases, no. However, investors should understand which institutions, platforms and providers are involved in their transactions.
6. Does using an international platform automatically increase sanctions risk?
No. The key consideration is who provides the service, how ownership is structured and whether any relevant party is subject to sanctions restrictions.
