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14 / 04 / 2023
From “friendly” to sanctions is just one step
What happened?

Russian citizens who opened bank accounts with the second-largest bank in the UAE, Emirates NBD (ENBD), have started receiving letters in which the bank warns of the introduction of sanctions restrictions and the creation of segregated accounts to enforce them. ENBD clarifies that the restrictions have been introduced pursuant to an “EU directive”.

Segregated accounts will be created for Russian citizens if they are not residents of the EU, the European Economic Area, or Switzerland. No exceptions are предусмотрено for Russians who have UAE residency.  

What do the introduced restrictions mean?


The assets of Russian citizens who do not fall under the above conditions will be transferred to a segregated account and “frozen.” Any coupons and dividends, as well as proceeds from the sale of securities, will be credited to this account, and any further transfer to their own active ENBD accounts for the subsequent use of assets and funds will be blocked.


What are these restrictions related to?

ENBD, like European and Swiss banks, has complied with the requirements of Clearstream and Euroclear after receiving a notification from them. This measure was introduced to avoid accusations that ENBD was violating the sanctions policies of the US, the EU, and Switzerland.

Is there any good news?

Yes, if one can call it that.

Other UAE banks have not yet received notifications from Clearstream and Euroclear and are not currently planning to take any action against Russian clients.

However, the risk that other banks in the UAE may also begin to join such restrictions with respect to Russian citizens cannot be ruled out.

What can we offer? 

ALPINE TAX can offer you the following services:

  • Assistance in obtaining a residence permit or residency in the EU or countries of the European Economic Area;

  • Assistance in creating a structure for the purpose of obtaining the right to use bank accounts at ENBD for investment purposes;

  • Assistance in opening bank accounts with other UAE banks or transferring assets from Clearstream and Euroclear to other depository and brokerage institutions (in particular, with a number of brokers in the UAE, the depository function is performed by entities in Hong Kong or Singapore);

  • Assistance in finding other “friendly” jurisdictions through which investment activities can be carried out while complying with Russian foreign exchange legislation. 


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