Raiffeisen Bank International subsidiary still invested in sanctioned Russian entities, find BankTrack and B4Ukraine, 12 March 2025

A fully consolidated Russian affiliate of Austria’s Raiffeisen Bank International (RBI) continues to hold and promote investments in numerous sanctioned Russian state and private entities, an investigation by BankTrack and B4Ukraine has revealed. 

Financial documents seen by BankTrack and B4Ukraine indicate that Raiffeisen Capital, a Russia-domiciled asset manager wholly owned by RBI’s Russian subsidiary AO Raiffeisenbank, continues to actively trade securities issued by the Russian government, state-owned energy giant Gazprom, and state-owned financial institution Sberbank, among others...

Raiffeisen Capital maintains 10 stock and bond-focused mutual funds, through which it invests clients’ money in curated portfolios of Russian and international securities. Several of its flagship funds include investments in key entities underpinning Russia’s war of aggression on Ukraine, according to financial reports available on the asset manager’s website.

Across its ten funds, the asset manager reported a total value of ca. 70.9 billion roubles (720 million USD) in January 2025. Of these assets, some 31.7 billion roubles (322 million USD) were invested in Russian entities that have been subject to US or EU sanctions for their involvement in the war on Ukraine.

Raiffeisen Capital reported about 1.6 billion roubles (16 million USD) of shares in Russian state-owned bank Sberbank, which has been subject to EU sanctions and restrictions since 2022 for its role in “financially supporting and benefitting from the Government of the Russian Federation.” The asset manager's other investments include some 2.2 billion roubles (22 million USD) worth of shares in state-owned gas enterprise Gazprom. Gazprom is a key target of US sanctions, and international observers have noted that the company remains a linchpin of Russia’s wartime economy and plays a crucial role in sustaining the war on Ukraine.

Most notably, financial filings indicate that Raiffeisen Capital maintains a series of investments in bonds issued by Russia’s Ministry of Finance. Russian state-operated ministries have been subject to sanctions by the US and EU as part of efforts to restrict the Russian government from raising additional funds for its war of aggression against Ukraine, with the European Union prohibiting trade in any transferable securities issued by the Russian government after 9 March 2022...

Raiffeisen Capital’s purchase of recently issued Russian Ministry of Finance bonds, in particular, may prove concerning for sanctions authorities. The European Commission’s complex guidance on its sanctions legislation places prohibitions on dealing with transferable securities issued by Russia and its government after 9 March 2022, “irrespective of whether the instruments are traded on secondary or primary market.” Raiffeisen Capital’s investments in more recent Russian government-issued bonds may therefore put the Austrian banking conglomerate at risk of falling foul of European sanctions regulations, which stipulate that EU companies must make “best efforts” to ensure their non-EU subsidiaries do not violate European sanction regimes.

In response to questions from BankTrack, a spokesman at Raiffeisen Bank International stated: “RBI has clearly stated that RBI wants to exit the Russian market with the sale of its Russian subsidiary AO Raiffeisenbank, including Raiffeisen Capital Russia. While working on the exit, RBI is reducing the Russian business in accordance with the requirements of the Austrian and European banking supervision. Further, please note that RBI maintains policies and procedures to be in compliance with all applicable EU, US and UK sanctions”...