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.
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.
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.
| Market | What happened | Date |
|---|---|---|
| Turkey | İşbank and Denizbank suspend Mir after a US Treasury warning; the three state-owned banks follow, and no Turkish acquirer accepts the scheme anymore | September 2022 |
| Kazakhstan | Halyk Bank, the country's largest bank, stops servicing Mir cards at ATMs and POS terminals | February 27, 2024 |
| All third countries | OFAC designates the NSPK itself under Executive Order 14024, with a wind-down period until April 8, 2024 | February 23, 2024 |
| Armenia | Armenian banks stop accepting Mir cards | March 30, 2024 |
| Kyrgyzstan | Elcard, the national scheme, keeps a Mir co-badged version for migrant workers in Russia | still in effect |
- 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.
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 category | Maximum rate | Maximum amount |
|---|---|---|
| Housing and utility services | 0,2 % | RUB 10 per transaction |
| Socially significant categories (healthcare, education, insurance, transportation…) | 0,4 % | RUB 1,500 per transaction |
| All other businesses | 0,7 % | RUB 1,500 per transaction |
| Person-to-person transfers (C2C) | free up to RUB 100,000 per month | above that: 0.5%, capped at RUB 1,500 |
| Transfers between your own accounts | free up to RUB 30 million per month | – |
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.
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.
| Swift | SPFS | |
|---|---|---|
| Type | Cooperative financial messaging network under Belgian law | Financial messaging run by the Russian central bank |
| What it carries | Instructions, not funds | Instructions, not funds |
| Reach | More than 200 countries and territories | Russia and correspondents in partner countries |
| Status for an EU operator | Permitted, except with Annex XIV entities under Regulation 833/2014 | Prohibited for EU entities outside Russia (Article 5ac) |
| Formats | MT and ISO 20022 (MX) | Russian format, MT-compatible |
| Settlement | None: settlement happens elsewhere | None: settlement happens elsewhere |
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.
| Regime | Legal basis | Practical effect | What it doesn't prohibit |
|---|---|---|---|
| EU asset freeze | Regulation (EU) 269/2014, annexes | Assets frozen; making funds available prohibited | Does not automatically mean Swift disconnection |
| Swift ban | Regulation (EU) 833/2014, Article 5h, Annex XIV | No more financial messaging with the institution | Does not freeze the institution's assets |
| US SDN List | Executive Orders 14024 and 13662 | Blocks any US interest; 50% ownership rule | Does not legally bind a European operator with no US nexus |
| Secondary sanctions | Executive Order 14114 of December 22, 2023 | A foreign financial institution can be designated for a significant transaction | Sets no numerical threshold for “significant” |
| SPFS ban | Regulation (EU) 833/2014, Article 5ac | EU entities outside Russia may not use SPFS | Does not cover use by non-EU third parties, except those in Annex XLIV |
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.
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.
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.
| Market | Dominant scheme or rail | Operator | Since |
|---|---|---|---|
| Uzbekistan | Uzcard and Humo | Common Republican Processing Centre; National Interbank Processing Centre | Humo: 2018 |
| Kazakhstan | Kaspi.kz (super-app), IPS and IMPS (public rails) | Kaspi.kz JSC; National Payment Corporation | IPS: 2022 · IMPS: July 19, 2026 |
| Kyrgyzstan | Elcard (cards) and ELQR (national QR) | Interbank Processing Center; National Bank of the Kyrgyz Republic | ELQR: 2022 |
| Tajikistan | Korti Milli, Alif Mobi wallet | National Bank of Tajikistan; Alif Bank | Korti Milli: 2017 |
| Armenia | ArCa, Idram and Telcell wallets | Armenian Card CJSC; Idram; Telcell | – |
| Azerbaijan | ICC (cards), IPS/AÖS (instant) | Central Bank of Azerbaijan | ICC: 2016 · IPS: 2020 |
| Georgia | GPSS (RTGS); instant rail announced | National Bank of Georgia | GPSS: 2001 |
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.
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.
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 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 prohibited | Legal basis | Since |
|---|---|---|
| Accepting deposits over €100,000 from a Russian national or resident | Regulation (EU) 833/2014, Article 5b, introduced by Regulation 2022/328 | February 26, 2022 |
| Providing financial messaging services to Annex XIV banks | Regulation (EU) 833/2014, Article 5h | March 12, 2022; lists extended since |
| Providing crypto-asset wallets, accounts, or custody to a Russian person, regardless of the amount | Eighth package, Regulation (EU) 833/2014 | October 6, 2022 |
| Using SPFS from an EU entity located outside Russia | Regulation (EU) 833/2014, Article 5ac | June 25, 2024 |
| Dealing with frozen banks, including the 94 institutions added in the latest package | Regulations (EU) 269/2014 and 833/2014 | July 23, 2026, for the latest extension |
- 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.
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.