Banking Issues – March 2026

The global political situation continues to have a significant impact on the banking sector. The war in the Middle East, its effect on Dubai as the region’s largest financial center, and Russia’s inclusion in the EU “black” AML list (similar to Iran and North Korea) are creating tangible difficulties in daily life. Below are the key findings based on conversations with clients and our own analysis.

Although news from Dubai is carefully filtered and authorities try to show that the conflict does not critically affect the financial system, companies offering consulting on setting up businesses and bank accounts in Singapore and Hong Kong have emerged online. These companies note that clients are gradually closing their investments in Dubai and transferring funds to these jurisdictions. There is no official data—both due to the war and because it is not in Dubai’s interest (penalties for publications considered harmful to the city’s image reach €23,000 or one year in prison). Without headlines, stability is already disrupted—money loves silence. In client conversations, we also noted that Dubai banks have strengthened checks and tightened compliance procedures for Russian clients.

Russia’s inclusion in the EU “black” AML list (since January 29, 2026) has led European companies working with Russian partners to have their accounts closed if the owners are European of Russian descent or Russians with permanent or temporary residence in the EU. Banks do not take into account that trade involves goods not subject to sanctions: any mention of Russia is automatically a reason to close personal and corporate accounts. This means that Russian citizens in Europe and other countries face additional restrictions even if they have permanent or temporary residence outside Russia.

Companies registered in Spain and Germany, where large Russian diaspora communities reside, remain without bank accounts and cannot open new accounts in the EU. Even payment institutions, through which significant transactions previously passed, no longer help.

Wealthy Russian clients can only conduct operations on their accounts after prior approval from the bank. There have been cases where approval for a luxury purchase took several days or weeks. Most often, only investment in the money market with limited capital movement is allowed. There is a real risk of personal funds being blocked, as happened with Russia’s foreign currency reserves, with AML potentially serving as an official justification for such measures.

It is important to note the rise in loan interest rates against the backdrop of looming liquidity shortages, weakening European real estate markets (one Swiss bank banned withdrawals from a real estate fund), and restrictions on fund withdrawals by several large Swedish private credit funds.

Given the current instability and the risk of your plan B failing, it is extremely important to prepare plan C now to protect your interests. Contact us to develop a reliable solution.