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As of of 05.05.2022 - Further updates will be made continuously

Payments

Show content of General impact on payment transactions

The United States, the United Kingdom and the EU are imposing sanction packages in rapid succession, with the next wave of sanctions already under discussion. This means that the impact on payment transactions is constantly changing and cannot be predicted with certainty. The sanctions that have already come into force and those that are under discussion have an impact on payment transactions. What this looks like in practice is determined by several factors and may be impacted by each company's individual situation, as well as the specific implementation status of the sanctions, all of which are currently evolving on an ongoing basis.

In principle, the following applies:

Several countries have imposed sanctions of varying scope against individual Russian banks. In addition, the EU has agreed to exclude certain banks from the SWIFT network. The publication of these measures is expected soon.

SWIFT is a cooperative society incorporated under Belgian law which provides, among other things, information services to the financial sector. More than 11,000 financial institutions from 200 countries worldwide use the SWIFT network to exchange financial messages. As SWIFT maintains operating centres in the United States and Switzerland, as well as other countries, it is subject to Belgian, European, Swiss and US sanctions laws. Affiliated banks may be subject to these and/or other sanction regimes as well, depending on their specific situations.

The SWIFT network enables banks to exchange messages with each other for the purposes of executing payment transactions and providing other financial services. Affiliated banks can be identified and contacted by their BIC (Business Identifier Code).

Excluding a bank from the SWIFT network means that this bank can no longer be contacted by other banks in the network via this route. As the messages in the closed SWIFT network are encrypted in a special way, the connected banks rely heavily on the binding nature of these messages. This is SWIFT's unique feature.

The exchange of SWIFT messages is particularly important in ensuring the smooth functioning of international payment transactions. Local payment systems, on the other hand, often function without the need to exchange SWIFT messages between the banks. This applies, for example, to the Russian payment system which processes the country's domestic payments.

It should be noted that sanctions have been imposed on individual Russian banks and prohibit transactions with these banks in general or in certain circumstances. Moreover, the EU has decided to exclude several banks from the SWIFT network with its Council Regulation 2022/345 of 1 March 2022. For more information please see "Which banks are affected from the SWIFT exclusion"

Status: 11.03.2022, 9 am CET

Show content of Does Deutsche Bank still execute transfers from and to Russia?

At present, Deutsche Bank generally executes cross-border payments to Russia – always with full consideration of imposed sanctions and possible risk assessments. In any case, it is expected that there will be restrictions in cross-border payments with Russia given the current developments. This is a factual statement and does not constitute a guarantee or commitment that a payment will be executed.

Status: 11.03.2022, 9 am CET

Show content of Which banks are affected from the SWIFT exclusion?

As of 12 March 2022, it is be prohibited to provide specialised financial messaging services for payments, which are used to exchange financial data (SWIFT) This affects the following banks or legal entities in Russia whose proprietary rights are directly or indirectly owned by these banks to more than 50 %: Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, VNESHECONOMBANK (VEB), VTB Bank. (see Council Regulation (EU) 2022/345 of 1 March 2022). 

As of 20 March 2022, it is prohibited

“to provide specialised financial messaging services, which are used to exchange financial data, to the legal persons, entities or bodies listed in Annex XV or to any legal person, entity or body established in Belarus whose proprietary rights are directly or indirectly owned for more than 50 % by an entity listed in Annex XV”.

Affected are:

  • Belagroprombank
  • Bank Dabrabyt
  • Development Bank of the Republic of Belarus

See Council Regulation (EU) 2022/398 of 9 March 2022

Status: 31.03.2022, 8pm CET

Show content of My company has accounts receivables in Russia for exported goods. Can these be paid?

Incoming payments from Russia require a case-by-case review which has to be taken into account by the involved parties (including the participating banks).

Show content of To and from which banks are payments no longer executed?

Payments are no longer executed to respectively from or via the below non-exhaustive list of banks. In general, majority-owned subsidiaries of sanctioned banks are also in scope. 

Russia

  • Central Bank of Russia (provided not as operator of local clearing system)
  • Vnesheconombank (‘VEB’)
  • Promsvyazbank PJSC (‘PSB’)
  • Bank Rossiya
  • Black Sea Bank for Development and Reconstruction
  • IS Bank
  • Joint Stock Company Genbank
  • VTB Bank PJS
  • Bank Otkritie Financial Corporation PJS
  • Sovcombank
  • Novikombank
  • SMP Bank
  • Sberbank & Alfa-Bank – additional information
  • Gazprombank (partly – see additional information below)

Belarus – state-owned banks (amongst others)

  • Belinvestbank
  • Belvnesheconombank (Belveb)
  • Bank Dabrabyt

Sberbank & Alfa-Bank – additional information

  • USA & Great Britain: In principle, payment transactions are stopped and blocked/rejected if Sberbank or Alfa Bank are in any capacity involved in the payment transaction chain (exception: certain wind down transactions and energy-related transactions as per licenses for Sberbank and to the extent visible in the transaction).
  • Other jurisdictions (e.g. EU): Incoming payments from the sanctioned parties are executed if not going to another sanctioned party. Incoming payments from the sanctioned parties are rejected, unless they are for our own clients (end beneficiary).

Gazprombank – additional information

  • USA & EU: In principle, payment transactions are executed unless they have a specific UK nexus (e.g. GBP payments) or are providing certain financing to Gazprombank.
  • Great Britain: Transactions are stopped and rejected/blocked in UK under asset freeze sanctions.

Under “sanctions and news“ you will find additional infos and links. Status: 05 May, 11:00 am CET

Show content of My business partner has an account with a bank in Russia which is not included on the sanction lists and the business partner wants to pay me cross border. Will the payment be accepted outside of Russia?

In any case, companies should expect restrictions and financial risks in cross-border payments.

If a cross-border payment is possible depends on whether:

  • the instructing party
  • the bank of the instructing party
  • the beneficiary
  • the bank of the beneficiary
  • an intermediate bank
  • the payment underlying business

is targeted by a respective sanction – from the perspective of a bank involved in the payment chain.

Even if, for example, the bank of the instructing party is not targeted by sanctions, but this bank can only pay cross-border out of Russia via a sanctioned correspondent bank, this payment would not be executed by banks outside of Russia – provided they are subject to the respective sanction regime. Moreover, there is the possibility that involved banks might not execute payments due to risk considerations. Therefore, restrictions in cross-border payments should be anticipated.

Companies should not expect payments to be executed only because the bank of the payer and the beneficiary are not included on sanction lists.

Status: 07.03.2022, 7:00 pm CET

Trade Finance

Show content of To what extend are letters of credit affected by the current developments in Russia and Ukraine?

In general, each letter of credit must be checked individually with different combinations to be considered: Is it an import or an export letter of credit? Which parties are involved (exporter, importer, associated banks), in which currency will the transaction be paid and what is the term?

Currently, the critical question is: Which sanctions are applicable to the letter of credit and the trade transaction? It is important to note that sanctions cannot only be directed against involved parties but also against goods and services that are being traded – and it cannot be ruled out that these sanctions impact the letter of credit as well.

Since the situation is extremely volatile, the feasibility of a transaction can change at any time and without notice. Sanctions can affect current and future business. Status: 04.03.2022, 12 pm CET

Show content of To what extend are guarantees impacted by the current developments in Russia and Ukraine?

In general, each guarantee must be checked individually with different combinations to be considered: Who is the beneficiary of the guarantee/counter guarantee and where is he located? Who is the warrantor/counter warrantor and where is he located? What is the currency owed, the term and the underlying business which should be secured? Who are the parties involved (exporter, importer, warrantor/return warrantor)?

Currently, the critical question is: Which sanctions are applicable to the guarantee/counter guarantee and the trade transaction? It is important to note that sanctions cannot only be directed against involved parties but also against goods and services that are being traded – and it cannot be ruled out that these sanctions impact the guarantee/counter guarantee as well.

Since the situation is extremely volatile, the feasibility of a transaction can change at any time and without notice. Sanctions can affect current and future business. Status: 04.03.2022, 12 pm CET

Interest rate and FX management

Show content of Are there restrictions with respect to FX transactions in RUB (offshore)? If so: Which ones?

Deutsche Bank will act in accordance with the implemented sanctions and measures and, if required, adjust settlement procedures respectively. From a regulatory point of view, there are currently no restrictions for offshore FX trade with EUR/RUB cash, forward transactions or cross-currency swaps. From a liquidity perspective one can see that the developments have had a strong impact on markets, the trading volume along the curve was much lower which has led to very short-term transactions. Therefore, there may be limitations to the volumes that are traded on the market. Status: 12.03.2022 01:00 pm CET

Show content of Are there restrictions with respect to on- or offshore derivatives?

The settlement of the offshore derivatives (e.g. for offshore customers that trade with Deutsche Bank offshore outside of Russia) as well as of the onshore derivatives (e.g. for onshore customers that trade with Deutsche Bank onshore inside Russia) are all carried out in accordance with the implemented sanctions and measures in the respective jurisdiction. Furthermore, all onshore derivatives are settled in a safe settlement modus, this means pre-funding is required. Status: 07.03.2022 11:00 am CET

Please read in this respect as well the question “My business partner has an account with a bank in Russia which is not included on the sanctions lists and the business partner wants to pay me cross border. Will the payment be accepted outside of Russia?” 

Disclaimer

The information, advice and estimates (“Information”) on this Deutsche Bank AG website have been prepared in a highly volatile environment and do not constitute investment, legal or tax advice. The United States, the United Kingdom and the EU are imposing sanction packages in rapid succession, with the next wave of sanctions already under discussion. This means that the impact on customers and the banking sector is constantly changing and cannot be predicted with any certainty. All information is therefore subject to change without notice and may differ from information that is or has been included in other documents published by Deutsche Bank, including research publications. All information is provided for information purposes only and without contractual or other obligation. No warranty is given as to the accuracy, completeness or adequacy of the foregoing information