Russian banks that are not under international sanctions have the option to use alternative channels instead of SWIFT for exchanging financial messages. This approach relies on different methods of transmitting payment instructions, ranging from traditional paper and fax to electronic mail, especially when banks are not directly blocked by EU measures. The European Union officials signaled this flexibility in statements dated February 28, noting that some banks may rely on non-SWIFT messaging channels to maintain cross-border payments with partner institutions.
One bank that could be affected by these developments is the Agricultural Bank of Russia. While the bank is not listed directly under EU blocking sanctions, its ability to use the SWIFT network to communicate with foreign counterparties has reportedly been disrupted. As a result, the institution may implement alternative messaging routes to continue essential overseas financial exchanges and settle payment orders with European banks through non-traditional channels. This shift helps preserve a degree of continuity in normal banking operations even when the standard international messaging system is not available.
Industry observers emphasize that when a credit institution is not targeted by EU blocking measures, it retains the right to adopt alternative means to transmit payment orders to counterparties. These channels can include non-specialized financial messaging services such as paper-based documents, fax transmissions, and electronic mail. The goal is to ensure that sanctioned-free trade and payments can proceed, even in the absence of SWIFT connectivity. In practice, this means banks can continue to settle transactions with foreign partners for activities that are not directly constrained by sanctions, provided counterparties accept the alternative methods and the transactions align with applicable rules and oversight.
From a broader perspective, the implication is that Russian banks not currently subject to EU sanctions can maintain bilateral operations with European lending institutions for the purpose of ordinary trade that falls outside the scope of export or import restrictions. This creates a continuing, though constrained, path for commerce and settlement in certain segments of the market. The EU sanctions framework aims to curb access to finance for institutions deemed to support governmental revenue or activities linked to the government, while still allowing non-sanctioned entities to pursue commerce that does not violate existing prohibitions. Analysts point out that the scope of tolerance for non-sanctioned entities hinges on careful compliance and ongoing scrutiny by European authorities to prevent circumvention of the sanctions regime.
In parallel developments on February 25, EU officials announced the tenth package of sanctions targeting Russia. The package expands restrictions on commercial and financial activities and includes several major Russian banks among those subject to tighter controls. Institutions cited as affected in the measures include Alfa-Bank, Rosbank, and Tinkoff, with officials asserting that these banks represent a significant source of government revenue and financial stability concerns for the Russian federation. The new measures are designed to limit the ability of these institutions to access global markets, complicate their liquidity management, and reduce their capacity to fund sensitive activities. The announcements underscore the EU’s ongoing effort to tighten financial leverage against entities that are viewed as facilitating or supporting political and economic objectives linked to state actors. This broader context helps explain why non-sanctioned banks may still need to rely on alternative messaging channels to support legitimate commerce with European counterparts, while ensuring that such activity remains within the legal boundaries set by the sanctions regime. [Citation: EU policy statements and official briefings dated February 25–28, 2025]