On 21/11/2025, it became known that the National Bank of Austria had decided to unblock the money transfer transactions for clients of L&P’s trustee bank, which had been “frozen” by an Austrian credit institution.
A number of payments for clients of L&P’s trustee bank were blocked back in 2022-2023, shortly after the active phase of the “sanctions war” began. This was due to the Austrian bank applying a policy of “overcompliance” – excessive and unjustified restrictive measures driven by its desire to minimize its own risks when dealing with individuals and assets connected to the Russian Federation and the Republic of Belarus. Building on the successful experience of unfreezing funds through administrative procedures in other European Union member states, L&P attorneys, together with colleagues from GRIMALDI ALLIANCE and the leading Austrian law firm GRAF ISOLA, decided to file a request with the National Bank of Austria demanding the removal of the imposed restrictive measures. In its response, the regulator avoided addressing the issue on its merits, granting Austrian credit institutions the right to independently decide on applying restrictive measures in each specific case. However, it confirmed our team’s assumption about the possibility of applying exemptions from the sanctions regime provided for by certain provisions of Council Regulation (EU) No 269/2014 in this situation.
In August 2025, a new request, prepared by attorneys from L&P’s sanctions law practice and our Austrian colleagues, was sent to the National Bank of Austria. This request demanded the unblocking of payments based on the updated version of Article 6b of Council Regulation (EU) No 269/2014. After several months of review, this request was fully granted by the regulator. In its decision, the National Bank of Austria recognized the validity of the stated claims and provided specific recommendations on the procedure for implementing its decision.
“Although work on this case has been ongoing for over two years, its successful conclusion underscores the exceptional importance of continuing the fight for our clients’ rights and legitimate interests. In the context of the continuous tightening of the sanctions regime and the desire of the European Union’s political leadership to completely block assets belonging to Russian and Belarusian individuals, the position of the National Bank of Austria is a rare example of exceptional professionalism and adherence to the rule of law. The achieved result was made possible thanks to the high level of professionalism and seamless teamwork of our Austrian colleagues and the attorneys from L&P’s sanctions practice,” notes L&P founder Alexander Linnikov, adding: “Now our team faces the task of ensuring the implementation of the regulator’s decision, and we are confident it will be successfully resolved in the very near future.”
