Interview: Navigating International Bank Transfers and Sanctions as a Mixed Russian-Foreign Couple

The safest way to move money between Russia and another country is to design a documented payment chain before sending: identify every bank and correspondent involved, confirm that none is sanctioned, obtain written acceptance where possible, and prepare evidence of the money’s source and purpose. A transfer may still be delayed or refused even when both spouses are non-sanctioned. Third-country accounts and declared cash can provide lawful alternatives, but neither should be used to conceal a Russian connection or circumvent sanctions.

Editorial interview: the magazine’s cross-border finance adviser explains the payment mechanics for mixed Russian-foreign couples.

Why a lawful family transfer can still fail

Q: Why has sending money to or from Russia become so difficult since 2022?

R: Three separate obstacles are often confused: sanctions law, payment-network access and a bank’s own risk policy.

Starting in March 2022, many major Russian banks were removed from SWIFT. The European Union widened the restrictions in subsequent sanctions packages, while US measures also reduced access to dollar clearing and correspondent banking. Yet SWIFT is only a secure messaging network. It does not itself hold or transfer money. A bank can theoretically exchange payment instructions through another channel and still be unable to settle the transaction because it lacks a usable correspondent account in euros or dollars.

A typical international transfer may involve:

• the sender’s bank;
• one or more correspondent banks;
• a currency-conversion or clearing institution;
• the recipient’s bank;
• sanctions and anti-money-laundering screening at several stages.

Any participant can stop the transfer. A French bank may approve a payment to a non-sanctioned Russian bank, only for an intermediary bank elsewhere in Europe to reject it because its internal policy excludes all Russia-related transactions. Conversely, the recipient bank may be legally able to receive euros but have no active euro correspondent willing to process them.

The EU Council’s consolidated Russia sanctions regulations identify prohibited relationships and listed parties. OFAC’s Russia-related sanctions FAQs explain the US restrictions, including how blocked entities and ownership rules are treated. Neither source says that every private transfer involving Russia is prohibited. Nevertheless, banks commonly apply enhanced due diligence to almost any Russian connection. Couples who also want to formalize how property and funds are owned between them, independently of these banking restrictions, often look into a notarized prenuptial agreement recognized under Russian and French law.

Q: Does marrying a Russian citizen expose the foreign spouse to sanctions?

R: No. Marriage to a Russian citizen does not place a foreign spouse on an EU, US or other sanctions list. Nationality and family status are not substitutes for individual designation.

A French wife of a Russian citizen, for example, does not become sanctioned merely because of the marriage. Nor is a Russian husband automatically sanctioned because he lives in Russia or uses a Russian bank. Screening should concern the actual individuals, entities, banks and ownership relationships involved.

There is an important nuance: a transaction can still be blocked if it directly or indirectly benefits a designated person, or if a company in the chain is owned or controlled by sanctioned parties under the applicable rules. A bank may therefore ask about relatives, business partners, employers or the ultimate beneficiary. That inquiry does not mean the spouse is personally listed.

The practical problem is usually country-level friction rather than personal designation. Banks may classify Russia-linked transfers as commercially unattractive because reviewing a €900 family-support payment can require almost as much compliance work as reviewing a much larger transaction.

Mapping the route before pressing “send”

Q: What should a couple ask their banks before initiating a transfer?

R: Do not ask only, “Can you send money to Russia?” That question is too broad and often produces an unreliable answer. Ask about the exact currency, recipient bank, correspondent route and payment purpose.

A useful pre-transfer inquiry should cover:

1. Is the recipient bank currently accepted?
2. Can the payment be sent in the chosen currency?
3. Which correspondent bank is expected to handle it?
4. Does the correspondent accept payments connected to Russia?
5. Are personal family-support, property or estate-related payments allowed?
6. What supporting documents must be submitted in advance?
7. Will fees be deducted from the principal?
8. What happens if the intermediary rejects or returns the payment?

The same questions should be put to the receiving bank. A bank may accept incoming yuan, for instance, but not euros. Another may accept foreign currency only into a designated account rather than the spouse’s ordinary ruble account.

The route should be mapped as follows:

Q: Is SPFS a replacement for SWIFT for mixed couples?

R: Only in limited circumstances. The Bank of Russia describes SPFS as its financial messaging system and reports connections by Russian and some foreign institutions. It can carry payment messages where participating banks have established the necessary arrangements.

That does not mean a foreign spouse can open an ordinary European banking app, select SPFS and send euros to Russia. Both institutions must be able and willing to use the system. They must also have a legal settlement mechanism for the chosen currency. Messaging and settlement remain different functions.

SPFS is therefore most relevant where a Russian bank has an established relationship with a foreign participating bank. It is not a universal substitute for lost euro or dollar correspondent access. Couples should obtain operational confirmation from both banks rather than relying on a general statement that a bank is “connected.”

Building a compliance file that a bank can understand

Q: What documents reduce the risk of a delay or refusal?

R: The bank needs to understand three things: who owns the money, where it came from and why it is being transferred. A coherent file is more effective than a large, disorganised collection of documents.

For recurring family support, the file might include:

• passports and residence documents for both spouses;
• a marriage certificate, with translation if requested;
• recent account statements showing the origin of the money;
• salary slips, tax returns or an employment contract;
• a short signed explanation of the payment’s purpose;
• evidence of the recipient’s ordinary expenses;
• previous correspondence in which both banks approved the route.

For larger or exceptional payments, add the document that created the funds. This could be a property sale agreement, court order, estate certificate, insurance settlement, dividend record or notarised gift agreement. Questions about ownership, matrimonial regimes and inherited property belong in a separate patrimonial analysis; the immediate payment issue is whether the bank can trace the funds from their legal source to the named recipient. See mixed couple inheritance documents for the underlying documentation.

Consistency matters. If a husband describes €25,000 as “family support” while the attached agreement shows that it is the deposit on an apartment, the discrepancy may trigger a review. Use a precise payment reference such as “monthly maintenance for spouse, July 2026” or “payment under apartment sale agreement dated [date].” Do not use vague wording such as “private transfer” when a clearer description is available.

Documents may need certified translations. Banks can also ask for updated material after initially approving a transfer, particularly if the amount differs from the couple’s usual account activity.

Q: Can a transfer be divided into smaller payments to avoid scrutiny?

R: Deliberately splitting one large transaction to remain below reporting or review thresholds is dangerous. Compliance systems detect repeated payments, common beneficiaries, matching references and unusual timing. The pattern may look like structuring, even when the underlying funds are legitimate.

There can be practical reasons to pay in instalments—for example, a property contract may require staged payments—but the documentation should explain them. The bank should see the contract, schedule and total amount.

A better strategy is to notify the bank before a large transfer. Ask the compliance department to review the documents and confirm whether the proposed route is acceptable. Approval is not guaranteed, and a front-line employee’s informal assurance may not bind a correspondent bank. It nevertheless creates a useful record that the couple acted transparently.

Couples should also check whether the transfer creates tax, foreign-account or residency reporting duties in either country. Those questions are separate from payment processing but often surface during compliance review. See mixed couple tax residency.

Third-country accounts, cards and physical cash

Q: Is opening an account in Georgia, Armenia, Kazakhstan, Turkey or the UAE a legitimate solution?

R: It can be, provided the account is lawfully opened in the account holder’s own name and the Russian connection is fully disclosed. These countries are frequently considered by mixed couples because some local banks maintain working links with both Russia and other international markets.

A typical route might be:

foreign spouse’s domestic account → foreign spouse’s account in a third country → Russian spouse’s bank account.

Each arrow is a separate transfer subject to screening. The intermediate account does not “clean” the transaction or remove its Russian destination. The third-country bank may request the marriage certificate, source-of-funds evidence, tax identification numbers and an explanation of why the account is needed.

Account availability also changes. Some banks accept only residents; others require local employment, a residence permit, a minimum balance or an in-person application. Fees and currency-conversion spreads can be substantial. A route that worked six months ago may close after the bank changes its correspondent relationships.

Using a friend’s or relative’s account is much riskier. It creates uncertainty about the beneficial owner, can breach account terms and may look like an attempt to conceal the parties. Couples should prefer an account legally owned by one of them, with an auditable sequence of statements. Further practical questions are covered at third country bank accounts.

Sanctions circumvention remains prohibited. A third-country account must not be used to hide a sanctioned bank, designated beneficiary or prohibited trade. Transparency is what distinguishes a lawful intermediate route from evasion.

Q: What about international cards outside the Visa and Mastercard networks?

R: Cards using other networks can be useful, but they are not a complete banking solution. Acceptance depends on the issuing bank, the card network, the country and the individual merchant or cash machine.

Since Visa and Mastercard suspended Russian operations, cards issued by Russian banks generally cannot use those networks abroad, while foreign-issued Visa and Mastercard cards generally do not operate inside Russia through the international networks. Couples sometimes use cards issued in a third country or cards on alternative international networks. Before relying on one, test:

• ordinary retail purchases;
• online payments;
• ATM withdrawals;
• transaction and conversion fees;
• geographic restrictions imposed by the issuer;
• whether the card can be replaced from abroad.

A card may solve daily spending without providing a reliable method for a house purchase, inheritance distribution or large family transfer. It should be treated as one tool in a broader plan.

Q: When is carrying cash lawful?

R: Cash can be lawful, but declaration thresholds are not permission to ignore separate sanctions or export controls.

When entering or leaving the EU through its external border, a traveller carrying €10,000 or more in cash must generally make a declaration. The EU definition of cash extends beyond banknotes in certain circumstances, and individual member states may impose additional controls, including on movements within the EU.

At the Russian/Eurasian customs border, cash and traveller’s cheques above the equivalent of US$10,000 generally require a written customs declaration. Amounts above the equivalent of US$100,000 require documents confirming the origin of the funds. The applicable rules and guidance should be checked immediately before travel through Russian customs and Central Bank of Russia materials.

A critical additional restriction has applied since 2022 to taking foreign-currency cash out of Russia: export above the equivalent of US$10,000 has been prohibited under Russian measures. Filing a declaration does not override that prohibition. Rules can change, and the currencies or instruments counted together must be checked for the actual travel date.

Keep bank withdrawal slips, sale agreements and customs copies. A traveller arriving with €30,000 from a documented property sale may still face detailed questions, but the position is much stronger than that of someone carrying the same sum without evidence.

What to do when a payment or account is frozen

Q: What does a “frozen” transfer actually mean?

R: The word covers several situations. A transfer may be paused for information, rejected before leaving the sender’s bank, held by a correspondent, credited into a restricted account, returned to the sender or legally frozen because a sanctions rule applies.

A false positive can arise because the customer shares a name or birth date with a listed person, because a Russian address triggers additional screening, or because the payment reference contains the name of a sanctioned bank that is not actually involved. Automated systems are intentionally cautious.

The first task is to identify where the money is. Ask for:

• the transfer reference and date;
• the exact payment status;
• the name of the institution holding or rejecting it;
• the reason code or compliance request;
• the deadline for supplying documents;
• confirmation of whether the funds are frozen, rejected or being returned.

A returned transfer may arrive short because intermediary and foreign-exchange fees have been deducted. It can also take longer to return than it took to leave the original account.

Q: How should a couple respond to a false-positive sanctions alert?

R: Use a structured remediation process rather than repeatedly telephoning customer service.

1. Request the issue in writing. Ask whether the block is based on sanctions law, missing information or internal risk policy.
2. Establish identity. Provide passport details, date and place of birth, address and any evidence distinguishing the customer from a similarly named listed person.
3. Document the source and purpose. Submit the relevant statements, contracts, marriage certificate and payment explanation.
4. Identify every party. List the sender, recipient, beneficial owner, banks and known correspondents.
5. Ask for escalation. Request review by the bank’s sanctions or financial-crime compliance team.
6. Preserve the record. Keep messages, submission receipts, reference numbers and document versions.
7. Use the formal complaint route. If there is no substantive answer, follow the bank’s complaint procedure and then the applicable national ombudsman, regulator or court route.

Do not attempt to resend the same payment through several banks while the first review is unresolved. Multiple parallel attempts can look more suspicious and may leave funds blocked in several places.

A bank may maintain its refusal even after confirming that no party is listed. This is the distinction between a legal freeze and a commercial rejection. A bank may have no obligation to accept a Russia-linked transfer that falls outside its risk appetite, although it should account properly for money already entrusted to it.

A workable payment plan for support, property and estate funds

Q: How should couples choose among the available routes?

R: Start with the purpose and amount, not with a fashionable payment workaround. A monthly living-cost transfer, an estate distribution and the proceeds of a Russian apartment sale require different planning.

For routine support, a modest recurring transfer through a pre-cleared bank route may be easiest to explain. Keep the amount and reference consistent, and retain proof that the recipient is the spouse. If direct transfers are unavailable, an account owned by the sender in a third country may provide a documented intermediate step.

For inheritance or another estate payment, the executor or paying institution should approve the route before distribution. The bank may need the death certificate, estate certificate, beneficiary identification and evidence that no designated person or restricted bank is involved. The inheritance itself may be lawful while the originally proposed payment route is unusable.

For property proceeds, involve the banks before signing or completing the sale. Russian rules for non-resident accounts and withdrawals have changed since 2022 and may depend on nationality, residency, currency and transaction type. The contract should not promise payment through a channel that the parties have not tested. Related mechanics appear at russia property sale payments.

A sound operating plan has five elements:

• Primary route: the preferred direct or third-country bank chain.
• Backup route: another pre-checked bank or currency, not an improvised hidden intermediary.
• Compliance file: identity, source-of-funds and purpose documents kept current.
• Timing margin: enough time for questions, rejection and return before a contractual deadline.
• Transaction record: statements, exchange rates, fees, declarations and bank correspondence.

Q: What is the most important principle for a mixed couple in 2026?

R: Make the transaction easy to understand. Banks are most uncomfortable when the route, ownership or purpose is ambiguous.

Before sending, write a one-page transaction summary: who is paying whom, how much, in which currency, for what reason, from what source, through which institutions and with which supporting documents. Check the relevant parties against the current EU Council consolidated sanctions regulations and, where US dollars or a US nexus is involved, the current OFAC Russia-related sanctions materials. Confirm operational details directly with every available bank in the chain.

Never assume that last year’s route remains open. Correspondent relationships, sanctions packages, Russian currency controls and internal bank policies can change without much notice. At the same time, do not assume that every family payment is illegal. Many are lawful; the challenge is finding a functioning route and documenting it well enough for each institution to accept.