Reference🇪🇺 Payments in EuropeIntermediate⏱ 25 min read

🇷🇺 Payments in Russia and the CIS

Mir and the NSPK after Visa and Mastercard pulled out, the SBP and its mandatory QR code, the Swift cutoff, SPFS, sanctioned banks, remittance corridors to Central Asia, and what a Western player can no longer do

March 2022: the loop closes

In March 2022, Visa and Mastercard suspended the processing of all transactions linked to Russia. Visa announced its decision on March 5, 2022, and Mastercard went public with its own the same day. The cutoff took effect on March 10 at 12:01 a.m. Moscow time. It had two immediate, mirror-image effects. Cards issued by Russian banks stopped working outside Russia, and cards issued abroad stopped working in Russia. Domestic payments, between a Russian cardholder and a Russian merchant, continued without interruption.

July 23, 2014
The NSPK is created
After the first Crimea-related sanctions, the Bank of Russia creates Natsionalnaya Sistema Platezhnykh Kart, the operator of the national switch. The law requires every card transaction made in Russia to be processed on its infrastructure.
2015
The Mir scheme launches
The NSPK launches a domestic card scheme. For seven years, it coexists with Visa and Mastercard without threatening them.
March 1, 2022
First Swift disconnections
Regulation (EU) 2022/345 bans the provision of financial messaging services to seven Russian banks: VTB, Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, and VEB.RF. It applies from March 12, 2022.
March 10, 2022
Visa and Mastercard exit
Russian cards stop working abroad, and foreign cards stop working in Russia. Domestic acceptance continues over the NSPK.
June 14, 2022
Sberbank is disconnected
Regulation (EU) 2022/1269 adds Sberbank, Credit Bank of Moscow, and Rosselkhozbank to Annex XIV. The country's largest bank loses Swift access.
July 23, 2026
21st EU sanctions package
The EU adds 33 Russian banks to the Swift ban and extends the asset freeze to 94 banks and financial institutions. The list includes institutions in third countries, among them two Indian subsidiaries of Sberbank and VTB.

Domestic acceptance kept working because of Federal Law No. 161-FZ on the National Payment System. The law, amended in 2014 after the first sanctions, requires card transactions made in Russia to be processed locally. Visa and Mastercard had therefore handed the domestic switch over to the NSPK eight years before they left. Their withdrawal affected only cross-border transactions, which that switch did not process, while domestic acceptance kept running on NSPK infrastructure. No acceptance outage was recorded in Russia.

March 10, 2022
Visa and Mastercard shut down in Russia
Visa Inc. and Mastercard, press releases of March 5, 2022
88,9 %
share of cashless payments in Russian retail
Bank of Russia, Q1 2026
493.9M
Mir cards issued
NSPK, April 1, 2026
RUB 103T
value processed by the SBP in 2025, across 18.3 billion transactions
Bank of Russia, 2025
🔑
A closed market, not a stalled one
Whether the Russian market is closed and how active it is at home are two separate questions, measured separately. Cashless payments reached 88% of retail in 2025, up from 85.8% in 2024 (Bank of Russia), so domestic use keeps growing year after year. Interoperability with foreign payment systems ended in March 2022, which leaves a Western payments company with no acceptance route into the market. The domestic ecosystem it cannot reach remains dense, regulated, and growing.

Mir and the NSPK: a closed-loop state scheme

Mir is Russia's domestic card scheme, launched in 2015 and operated by the NSPK, a subsidiary of the Bank of Russia. It was created by political decision, not in response to market demand. The scheme's CEO claimed about 85% of the Russian card market in 2025, and 493.9 million cards had been issued as of April 1, 2026. Issuance is driven by a legal requirement: public-sector salaries, pensions, and social benefits are paid onto Mir cards. Acceptance was already universal before 2022, since every terminal in the country had been connected to the NSPK.

Mobile payments are payments made with a wallet built into the phone, whether contactless in store or online. Apple Pay and Google Pay pulled out of the Russian market in 2022. Mir Pay, the NSPK's NFC wallet, was available to customers of 176 Russian banks at the end of 2024. It exists only on Android. iPhone users have no NFC payment option in Russia, and no regulation removes that technical barrier. TBank handed out NFC stickers to its cardholders to work around it. SberPay, T-Pay, and Yandex Pay serve the same need on Android and online. The lack of a contactless wallet on iOS explains the ground gained by QR codes, covered in the next section.

MarketWhat happenedDate
Turkeyİşbank and Denizbank suspend Mir after a US Treasury warning; the three state-owned banks follow, and no Turkish acquirer accepts the scheme anymoreSeptember 2022
KazakhstanHalyk Bank, the country's largest bank, stops servicing Mir cards at ATMs and POS terminalsFebruary 27, 2024
All third countriesOFAC designates the NSPK itself under Executive Order 14024, with a wind-down period until April 8, 2024February 23, 2024
ArmeniaArmenian banks stop accepting Mir cardsMarch 30, 2024
KyrgyzstanElcard, the national scheme, keeps a Mir co-badged version for migrant workers in Russiastill in effect
Documented timeline of Mir's loss of acceptance outside Russia
⚠️
Treat Mir as a sanctions risk, not a network
The NSPK has been on OFAC's SDN list since February 23, 2024. Any foreign financial institution that processes significant transactions with it risks secondary sanctions under Executive Order 14114. The EU's 21st package, adopted in July 2026, names a Chinese bank that still uses Russian payment systems, including Mir. Accepting the scheme is therefore a question of institutional risk policy. The decision belongs to the board, not to the acceptance teams.
  • No Western acquiring contract routes Mir. The scheme has no licensing agreement with European acquirers, and will have none as long as the NSPK remains designated.
  • Mir BINs are identifiable and must be blocked before routing, not left to an issuer decline: any attempt that gets processed leaves a transaction record.
  • Mir co-badging is an identification trap. A Kyrgyz Elcard card can carry both brands, and domestic routing and Mir routing do not carry the same risk.
  • Russian wallet tokens do not work outside the NSPK ecosystem: there is no e-commerce acceptance route from a European PSP.

The SBP: QR codes versus cards

The Faster Payments System, or SBP (Sistema Bystrykh Platezhey), is the Bank of Russia's instant payment rail, operated by the NSPK since 2019. It handles account-to-account transfers by phone number and merchant payments by QR code. Adoption was driven by regulation: the central bank made participation mandatory for systemically important banks. That mandate ended Sberbank's dominance of person-to-person transfers, since customers could now send money between banks using just a phone number. The SBP had 226 participating banks as of June 1, 2026.

4.7B
SBP transactions in Q1 2026, up 14% year over year
Bank of Russia, Q1 2026
RUB 26.5T
value exchanged over the SBP in Q1 2026, up 17% year over year
Bank of Russia, Q1 2026
1.4B
merchant payments (C2B) in Q1 2026, worth RUB 2.4 trillion: 29% of transactions by number and 9% by value
Bank of Russia, Q1 2026
226
participating banks
Bank of Russia, June 1, 2026

The Bank of Russia caps merchant fees on the C2B channel, setting both the rate and the maximum amount per transaction. No equivalent rule applies to card acquiring in Russia, where pricing is unregulated. The fee schedule distinguishes several merchant categories: utilities and socially significant activities pay less than ordinary retail. The absolute cap kicks in on large tickets, and the fee stops rising above about RUB 214,000.

Merchant categoryMaximum rateMaximum amount
Housing and utility services0,2 %RUB 10 per transaction
Socially significant categories (healthcare, education, insurance, transportation…)0,4 %RUB 1,500 per transaction
All other businesses0,7 %RUB 1,500 per transaction
Person-to-person transfers (C2C)free up to RUB 100,000 per monthabove that: 0.5%, capped at RUB 1,500
Transfers between your own accountsfree up to RUB 30 million per month–
Capped merchant fees on the SBP (Bank of Russia rules)
A merchant QR payment on the SBP
Merchant
Displays a QR code
Static QR at the register, or a dynamic QR generated for the exact sale amount
Customer
Scans it in their banking app
Any participating bank, or the NSPK's SBPay app
Payer’s bank
Debits the account, not a card
No card data enters the chain: no PAN, no token, and no tokenization to revoke
NSPK
Routes and clears the transaction
Confirmation within seconds, 24 hours a day, including weekends and public holidays
Merchant's bank
Credits the merchant's account
Fee capped at 0.4% or 0.7% depending on the category, versus uncapped card acquiring

Choosing between QR and card comes down to three factors: transaction cost, settlement time, and the features the QR channel lacks. The QR channel costs 0.4% or 0.7%, with a hard cap of RUB 1,500 per transaction, while banks remain free to set card acquiring prices. Settlement is immediate, account to account, with no clearing delay. On the other hand, the QR channel offers no pre-authorization, no delayed capture, and no standardized dispute process. A refund is an outgoing transfer that only the merchant can initiate. Businesses that rely on reservations and on adjusting the amount later, such as hotels and rentals, therefore stay on cards.

ℹ️
The universal payment code, from September 1, 2026
Federal Law No. 248-FZ of July 23, 2025, creates a universal payment code, operated by the NSPK free of charge. A single QR code sits at the register, whatever instrument is used to pay. The customer scans it, then picks from a single page: the SBP, their bank's own payment service, an installment plan, or the digital ruble. The first wave applies from September 1, 2026, to systemically important banks and to merchants with annual revenue above RUB 120 million. The requirement then expands on September 1, 2027, and again on September 1, 2028. From that point on, the big banks' proprietary QR codes no longer have the register to themselves.

Swift, SPFS, and fallback messaging

Swift is a cooperative financial messaging network. It carries payment instructions between banks, but it does not move funds. Disconnecting an institution cuts off that instruction channel without touching the assets themselves. A disconnected bank keeps its correspondent accounts, but loses the standardized channel it used to send instructions to those correspondents. The Russian banks affected switched to telex, proprietary bilateral channels, and SPFS. The messaging ban and the asset freeze are two separate measures, and they do not always target the same institutions.

SPFS (Sistema Peredachi Finansovykh Soobshcheniy) is the Bank of Russia's financial messaging system. It opened in 2014, eight years before the disconnections it was designed to absorb. It carries messages in a Russian format and also accepts Swift MT formats. It is not a settlement system. Final settlement still runs through Bank of Russia systems and correspondent accounts, in rubles and in partner-country currencies. About 550 organizations were connected in January 2024, only a small share of them foreign. That figure comes from a secondary source and must be cross-checked before any contractual use.

SwiftSPFS
TypeCooperative financial messaging network under Belgian lawFinancial messaging run by the Russian central bank
What it carriesInstructions, not fundsInstructions, not funds
ReachMore than 200 countries and territoriesRussia and correspondents in partner countries
Status for an EU operatorPermitted, except with Annex XIV entities under Regulation 833/2014Prohibited for EU entities outside Russia (Article 5ac)
FormatsMT and ISO 20022 (MX)Russian format, MT-compatible
SettlementNone: settlement happens elsewhereNone: settlement happens elsewhere
Swift and SPFS: what compares and what doesn't
⚠️
Article 5ac: connecting to SPFS is prohibited, not just risky
The EU's 14th package, adopted on June 24, 2024, added Article 5ac to Regulation (EU) 833/2014, effective June 25, 2024. The article bars EU entities established outside Russia from using SPFS. The exemptions are narrow: they cover certain energy payments and the repayment of claims held by EU nationals. The same article paves the way for a ban on dealing with third-country banks connected to SPFS, listed in Annex XLIV. In November 2024, OFAC issued an alert warning that institutions joining the system would be targeted. For a European banking group, connecting to SPFS is therefore prohibited outright, not just a matter of risk management.

The 21st package, adopted on July 23, 2026, extends EU restrictions to about half of the Russian banking sector. It adds 33 banks to the Swift ban and extends the asset freeze to 94 banks and financial institutions. The list also reaches further geographically: it includes a Mongolian bank, two Indian subsidiaries of Sberbank and VTB, and a Chinese institution. Circumvention through third-country institutions is now the regime's main target.

Reading the map of sanctioned banks

Restrictions on a Russian bank fall under three legal regimes that overlap without coinciding. A bank can be cut off from Swift without having its assets frozen. It can be frozen by Washington but not by Brussels, or be subject to sectoral restrictions without appearing on any named list. A compliance dashboard that treats these layers as a single list generates costly false positives and, worse, lets through counterparties that only one regime covers. A counterparty's status also depends on the date it is assessed. Gazprombank stayed off the US list for nearly three years, until it was designated on November 21, 2024.

RegimeLegal basisPractical effectWhat it doesn't prohibit
EU asset freezeRegulation (EU) 269/2014, annexesAssets frozen; making funds available prohibitedDoes not automatically mean Swift disconnection
Swift banRegulation (EU) 833/2014, Article 5h, Annex XIVNo more financial messaging with the institutionDoes not freeze the institution's assets
US SDN ListExecutive Orders 14024 and 13662Blocks any US interest; 50% ownership ruleDoes not legally bind a European operator with no US nexus
Secondary sanctionsExecutive Order 14114 of December 22, 2023A foreign financial institution can be designated for a significant transactionSets no numerical threshold for “significant”
SPFS banRegulation (EU) 833/2014, Article 5acEU entities outside Russia may not use SPFSDoes not cover use by non-EU third parties, except those in Annex XLIV
Layers of restrictions on a Russian bank counterparty

Executive Order 14114, signed on December 22, 2023, creates a secondary sanctions regime for third-country banks. It authorizes OFAC to designate any foreign financial institution that has conducted or facilitated a significant transaction involving Russia's military-industrial base. On June 12, 2024, OFAC broadened that definition to any person blocked under Executive Order 14024, which covers nearly all large Russian banks. A Kazakh or Emirati bank that processes payments for Sberbank now falls within the order's scope. The wave of withdrawals seen in Central Asia stems from this order, not from primary sanctions.

  • Test ownership, not just the name. The US 50% rule captures unlisted subsidiaries. The EU applies its own ownership and control test, which can produce a different result.
  • Date every decision. A counterparty that was lawful in 2023 is not necessarily lawful in 2026: the 20th package of May 14, 2026, added 20 Russian banks, and the 21st added 33.
  • Separate messaging from funds in your controls: blocking a disconnected BIC is not enough if the assets are not frozen, and vice versa.
  • Monitor third-country entities. Subsidiaries of Russian banks in India, as well as Mongolian and Chinese institutions, now appear on EU lists.
  • Document any exemption you rely on. The energy exemptions under Article 5ac are narrow and must be justified document by document.
⚠️
The risk has moved to the correspondent bank
European payment service providers cut their direct ties with Russian banks in 2022. The remaining risk sits with correspondent banks in Central Asia, the Caucasus, or the Gulf that execute payments for customers whose beneficial owner is Russian. Due diligence therefore has to cover that correspondent bank's risk profile, the corridors it serves, and its policy on Russian flows. Screening only the beneficiary against sanctions lists will not reveal this exposure.

Corridors to Central Asia and the Caucasus

The Russia–Central Asia corridor carries the money that migrant workers in Russia send home. It is one of the most concentrated remittance flows in the world. In 2024, remittances equaled 45% of Tajikistan's GDP, 24% of Kyrgyzstan's, and 14% of Uzbekistan's (World Bank). More than 80% of Tajik and Kyrgyz migrants were heading to Russia in 2023. No diversification can offset that dependence in the short term. Financial sanctions therefore hit household incomes in all three countries, not just the banks they target.

$18.9B
remittances received by Uzbekistan in 2025
Central Bank of Uzbekistan, 2026
72,4 %
Russia's share of remittances received by Uzbekistan in Q1 2026, vs. 77.6% a year earlier
Central Bank of Uzbekistan, labor market review, 2026
45 %
migrant remittances as a share of Tajikistan's GDP, the highest in the world
World Bank, 2024
$9.3B
remittances received by Uzbekistan in H1 2026, up 13% year over year
Central Bank of Uzbekistan, 2026

Zolotaya Korona, marketed as Korona Pay and developed by the Center for Financial Technologies (CFT), is the traditional channel for these remittances. After Visa, Mastercard, and Western Union pulled out in 2022, it became one of the few viable routes. OFAC designated the CFT in August 2024, and the EU listed the system's settlement bank in July 2026. Partner banks reacted immediately, but not all in the same way. Kapitalbank, Asakabank, Agrobank, Aloqabank, and Asia Alliance Bank suspended transfers in Uzbekistan, while BankCenterCredit, Bereke Bank, and Nurbank were still processing them in Kazakhstan at the end of July 2026. The channel's availability therefore varies from bank to bank within the same country.

A transfer in this corridor has three successive links. The worker deposits cash or debits a Russian account at a licensed operator, which then settles with its local counterpart over an interbank channel. The recipient withdraws local currency at a branch, or receives the funds on a domestic card. Each of the three links can break on its own, for unrelated reasons. The Russian link breaks when the operator loses its license. The interbank link breaks when the settlement bank is designated. The local link breaks when the receiving bank pulls out on its own initiative. Monitoring this corridor therefore means tracking all three links, not the service's brand name.

MarketDominant scheme or railOperatorSince
UzbekistanUzcard and HumoCommon Republican Processing Centre; National Interbank Processing CentreHumo: 2018
KazakhstanKaspi.kz (super-app), IPS and IMPS (public rails)Kaspi.kz JSC; National Payment CorporationIPS: 2022 · IMPS: July 19, 2026
KyrgyzstanElcard (cards) and ELQR (national QR)Interbank Processing Center; National Bank of the Kyrgyz RepublicELQR: 2022
TajikistanKorti Milli, Alif Mobi walletNational Bank of Tajikistan; Alif BankKorti Milli: 2017
ArmeniaArCa, Idram and Telcell walletsArmenian Card CJSC; Idram; Telcell–
AzerbaijanICC (cards), IPS/AÖS (instant)Central Bank of AzerbaijanICC: 2016 · IPS: 2020
GeorgiaGPSS (RTGS); instant rail announcedNational Bank of GeorgiaGPSS: 2001
Domestic rails in the region: what payments actually run on
🇰🇿
Kazakhstan: a private super-app ahead of the state
Kaspi.kz, listed on Nasdaq, processed KZT 11,353 billion ($23.7 billion) in payments in Q1 2026, up 14% year over year. Its dominance led the central bank to mandate an interoperable interbank QR code, and then to launch IMPS on July 19, 2026, with every bank offering retail mobile services connected from day one.
🇺🇿
Uzbekistan: a duopoly forced open
Until 2023, an Uzcard cardholder could not withdraw cash from a Humo ATM. The regulator mandated interoperability. The state's stake in Humo was sold to Paynet for $65 million in January 2025, and the scheme claims more than 27 million cards issued.
🇰🇬
Kyrgyzstan: the national QR as the foundation
ELQR, launched by the central bank in 2022, had more than 67,000 QR codes deployed and 121 million cumulative transactions worth KGS 182.4 billion as of April 1, 2025. Every bank in the country accepts the same merchant QR code.
🇬🇪
Georgia: no retail instant rail
The central bank's GPSS migrated to ISO 20022 on May 11, 2026, on a Montran platform. The retail instant rail is still slated for the end of 2026. Until then, everyday payments run on cards and on the banks' own apps, which explains the unusual weight of local banking super-apps.
⚠️
Ruble stablecoins: a corridor that can lead back to you
The A7A5 token is a ruble-backed crypto-asset. OFAC sanctioned it in August 2025, along with the Kyrgyz companies A7 LLC and Old Vector and the Grinex exchange, Garantex's successor. Ilan Shor and Promsvyazbank, an already designated Russian bank, hold a majority stake. Reported volumes run into the tens of billions of dollars, and a European crypto-asset service provider must trace its indirect exposure to this token. Receiving funds that originate from a sanctioned asset requires no direct relationship with Russia. Because on-chain transfers are recorded, that path can be reconstructed after the fact and the funds tied back to a sanctioned asset.

Belarus mirrors Russia, Moldova goes the other way

The Belarusian market went through the same rupture as Russia's, on a smaller scale and with fewer resources. Three banks lost Swift access in March 2022: Belagroprombank, Bank Dabrabyt, and the Development Bank of the Republic of Belarus. Belinvestbank followed in June 2022, and in July 2025 the EU turned these restrictions into a ban on all transactions with those institutions. Visa and Mastercard left the market. Since then, the country has run entirely on domestic rails.

  • BELKART, the national card scheme, operated by the bank processing center ОАО “Банковский процессинговый центр” under the National Bank's authority. It has been the country's only fully functional card rail since 2022. Its BELKART Pay app is available on Google Play and AppGallery, but never on iOS.
  • ERIP (2008), the Single Settlement and Information Space, a national bill payment hub where school fees, energy bills, fines, and subscriptions can be paid from any bank. This hub, not direct debit, is the backbone of bill payment in Belarus.
  • BISS, the National Bank's real-time gross settlement system, run by the interbank settlement center. Clearing balances from adjacent systems, including ERIP, settle there.
  • Оплати (Oplati) (2018), an e-money-based QR and transfer service open to customers of any bank. Because it is interoperable with SBP and Sber QR codes, it is one of the few retail payment bridges between the two countries.

Moldova built its payment infrastructure in the opposite direction, opening it to non-bank players from the start. The Banca Națională a Moldovei directly operates the SAPI core, which combines real-time gross settlement for large-value payments with deferred net settlement for bulk payments. In 2023, the central bank launched the MIA instant rail. It supports QR payments, transfers by phone number, payment links, and transfers between accounts held by the same person. Payments execute in 10 seconds or less, 24 hours a day. More than 15 providers were connected in 2026, including non-bank payment institutions such as Paynet and Bpay. The limit is MDL 5,000 per transaction, and transfers are free up to MDL 10,000 a month.

ℹ️
Two responses to the same constraint
Belarus and Moldova built national instant rails over the same period, but took opposite directions. Belarus turned inward on its domestic rails and made them interoperable with Russia's. Moldova opened its rails to non-bank payment institutions from the start, which is still rare for a market that size, and its architecture follows European standards. A Western player can therefore sign contracts in Moldova, while the Belarusian market remains closed to it.

Digital ruble: adoption mandated by law

The digital ruble is Russia's central bank digital currency, and its pilot is still limited to a small number of banks. What sets it apart from other central bank digital currencies (CBDCs) is not its technical progress but its adoption path. The law sets a mandatory acceptance timeline, calibrated to bank size and merchant revenue. The pace of rollout is therefore driven by legal deadlines, not by demand from banks or merchants.

September 1, 2026
First wave
Systemically important banks must offer the digital ruble to their customers. Merchants with annual revenue above RUB 120 million must accept it. The NSPK's universal payment code becomes mandatory at the same time.
September 1, 2027
Second wave
Extended to banks with a universal license and to merchants with revenue above RUB 30 million.
September 1, 2028
Third wave
Extended to banks with a basic license and to merchants with revenue of RUB 20 million to 30 million.
Permanent exemptions
What stays out of scope
Merchants with revenue below RUB 5 million and points of sale in areas without internet access are exempt.

The digital ruble and the universal payment code take effect on the same date, and the Bank of Russia presents the two projects as linked. The universal payment code shows customers a single page where they choose how to pay. The digital ruble appears there alongside the SBP, their bank's own payment service, and installment plans. Russia's CBDC therefore doesn't have to win its place at the register: it shows up in a channel the law already requires merchants to offer. Through that channel, small banks gain a presence at the register that they could not have paid for on their own.

🔑
What this timeline tells outside observers
No other major economy has written into law a requirement to accept a central bank digital currency, phased in over three years. The Russian timeline is therefore the first observable case for regulators weighing a digital euro or other retail digital currencies. Two data sets will show how far it goes. The first is actual usage once acceptance is mandatory. The second is the integration cost borne by merchants in the second and third tiers. Requiring merchants to accept an instrument does not determine how much consumers will use it.

What a Western player can no longer do

A European payment operator's residual exposure consists of flows that reach Russia without any direct contractual relationship with a Russian counterparty. Direct bans have been in force since 2022. Residual exposure now sits in remittance corridors, in beneficial ownership checks, and with second-tier correspondents. The table below lists the EU bans that define this scope, with their legal basis and effective date.

What is prohibitedLegal basisSince
Accepting deposits over €100,000 from a Russian national or residentRegulation (EU) 833/2014, Article 5b, introduced by Regulation 2022/328February 26, 2022
Providing financial messaging services to Annex XIV banksRegulation (EU) 833/2014, Article 5hMarch 12, 2022; lists extended since
Providing crypto-asset wallets, accounts, or custody to a Russian person, regardless of the amountEighth package, Regulation (EU) 833/2014October 6, 2022
Using SPFS from an EU entity located outside RussiaRegulation (EU) 833/2014, Article 5acJune 25, 2024
Dealing with frozen banks, including the 94 institutions added in the latest packageRegulations (EU) 269/2014 and 833/2014July 23, 2026, for the latest extension
EU bans that shape a payment operator's exposure
  • No acceptance contract lets a European PSP take Mir cards: this is not something a technical integration can solve.
  • Remittance corridors are unstable, bank by bank. An Uzbek partner that processed Korona Pay in June 2026 may have stopped by July. Recheck the channel's availability before every settlement cycle.
  • Subsidiaries of Russian banks outside Russia are targeted. Two Indian subsidiaries of Sberbank and VTB appear in the July 2026 package: a screen limited to entities incorporated under Russian law will miss them.
  • Ruble-backed crypto-assets create indirect exposure without any contractual relationship with a Russian counterparty. On-chain traceability makes that exposure provable after the fact.
  • Ownership tests differ between regimes. The US 50% rule and the EU ownership and control test do not always produce the same result for the same structure.
  • Document your exemptions. Exemptions for energy payments and claim repayments exist, but they are narrow and must be proven case by case.
⚠️
The most common trap: an outdated payment methods database
Many internal catalogs still list Russian payment methods that no longer exist. Qiwi is the textbook example. The Bank of Russia revoked Qiwi Bank's banking license on February 21, 2024, for repeated anti-money laundering violations. The wallets stopped working, the terminals shut down, and the Contact money transfer system was removed from the register of payment systems. Sales material that still lists this service describes an offering that has been gone since 2024, and shows a payment methods database that nobody has reviewed in two years.

Russian residents paying for European online services is a question that comes up at every risk committee. Since March 2022, no Russian-issued card has had an authorization path to a European acquirer. Payments that do go through rely on intermediaries in third countries, which collect from the customer in rubles and then pay the merchant from a foreign entity. A European merchant can therefore receive Russian flows without knowing it. The warning sign is unusual volume growth from an Armenian, Kyrgyz, or Emirati aggregator, and it is up to the merchant to act on it.

The reverse case, a Russian merchant trying to accept payments abroad, rarely comes up in practice. Still, in April 2024, the Bank of Russia acknowledged that it was working on ways around the loss of card acceptance. It cited two: subsidiaries of Russian banks based abroad, and SBP gateways to local payment solutions. Two years later, neither route has produced a cross-border retail rail at scale. The Russian market collects payments very efficiently at home, and almost nowhere else.