To:
Dr. Ursula von der Leyen
President of the European Commission
Rue de la Loi / Wetstraat 200
1049 Brussels
Belgium
Date: April 16, 2025
Subject: Request for Sanctions and Equal Treatment Under Articles 18, 19, and 21 of Treaty on the Functioning of the European Union
Dear President von der Leyen,
We are writing to you in our capacity as the members of the Executive Board of the Belarus Democratic Forum in order to express serious concern over the selective application of European Union sanctions, particularly in regard to Raiffeisen Bank International AG (RBI). The bank’s ongoing operations and financial entanglements in Russia and Belarus—conducted without consequence—represent a serious breach of the EU’s legal and moral commitments under the Treaty on the Functioning of the European Union (TFEU) and the Charter of Fundamental Rights of the European Union (CFR).
I. Complicity in Russia’s War Efforts
Since the beginning of Russia’s full-scale invasion of Ukraine, over 1,000 companies have exited the Russian market, including Deutsche Bank, Citigroup, HSBC, Société Générale and others. Raiffeisen Bank International has chosen to remain in Russia and profit from its war economy. According to Forbes, in 2024 RBI is ranked as one of Russia’s top three “most reliable systemically important banks” — alongside Sberbank and VTB - https://www.forbes.ru/society/533027-12-samyh-nadeznyh-rossijskih-bankov-2025 .
Raiffeisen with its 124 branches across Russia, holding millions of accounts, and processes state taxes despite its deep and ongoing involvement in the Russian economy — and even its servicing of companies that supply chemical components used in missiles targeting Ukrainian civilians continues to operate unrestricted within the EU financial system (https://www.bloomberg.com/news/articles/2025-02-03/).
It remains the only financial institution operating freely in both Russia and the European Union, with profits from its Russian operations exceeding the combined earnings of its 12 EU-based subsidiaries. In 2024 RBI earned €873 million in profit from its Russian operations amounting to over 75% of its global income. This means that RBI has effectively transformed into a de facto Russian bank with remaining Austrian registration, generating the bulk of its profits from a jurisdiction under international sanctions.
While the European Union has committed €132 billion in aid to Ukraine, RBI’s continued operations in Russia directly counteract these efforts—undermining EU foreign policy and diminishing the impact of European taxpayers’ contributions to Ukraine’s defense and recovery.
II. Complicity in Persecutions in Belarus
Acting on the guidance and recommendation of Raiffeisen Leasing, Valery Tsepkalo—2020 presidential candidate—and Veronica Tsepkalo—recipient of the Charlemagne Prize, the Sakharov Prize of the European Parliament, the John McCain Freedom Award, and the Martin Luther "Fearless Word" Prize entered into a reverse leasing agreement with Raiffeisen Bank International (RBI). Under this agreement, RBI became the de jure legal owner of the family’s residence in Minsk, with a contractual obligation to retain ownership and return the property to the family in 2040.
However, in 2024, RBI unlawfully transferred the property to the Belarusian regime, which subsequently placed it under a politically motivated auction process. This action was taken without invoking the legally binding investor protections guaranteed by the Austria–Belarus Bilateral Investment Treaty (BIT) and the existing investment agreement between RBI and the Belarusian government.
The property serving as the family’s sole residence—was sold at a drastically undervalued price after four failed auction attempts, depriving a mother and her two 12-year-old children of their only home.
By enabling this act, RBI became complicit in serious violations of international human rights and corporate responsibility standards, including the UN Convention on the Rights of the Child (CRC), the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR). RBI also breached its obligations under key corporate governance frameworks, such as the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the EU’s Corporate Sustainability Due Diligence Directive (CSDDD).
By enabling the forced dispossession of a politically persecuted family and failing to protect the property through accessible legal mechanisms such as Belarus Austrian Investments Protection Treaty and Investment agreement between Raiffeisen and the government of Belarus RBI acted in direct violation of its legal and ethical obligations as a financial institution headquartered in the European Union. It joined the Lukashenko regime in sending a clear message: that those who defend human rights will face punishment and loss along with their families and minor children.
III. A Sham Exit from Belarus
These actions gained further clarity in light of subsequent developments. In November 2024, RBI announced the sale of its Belarusian subsidiary, Priorbank, to Soven 1 Holding Limited—a UAE-based shell company with no financial history, whose nominal director is Suhail Al Otaiba. Al Otaiba, who lacks the financial capacity to manage such a transaction, is reportedly linked to Viktor Lukashenko, son of Belarusian dictator Alexander Lukashenko. This covert transaction was conducted in violation of core European Union financial and market integrity laws, including the Market Abuse Regulation (EU 596/2014), the Prospectus Regulation (EU 2017/1129), and the Transparency Directive (2004/109/EC), which requires consistent and accurate financial reporting by listed companies.
RBI’s financial reporting related to the sale shifted dramatically — from an initially declared loss of €300 million to €830 million in just two months — a deviation that would be unthinkable for any publicly listed company, especially in the absence of a disclosed sale price or a credible explanation for the discrepancy. This striking lack of transparency, combined with the dubious nature of the buyer, strongly suggests that RBI entered into a concealed arrangement with members of the Lukashenko family. There is substantial reason to believe that senior RBI leadership retains undisclosed interests in the deal.
IV. Selective Sanctions and Ethnic Disparities
If individuals like Mikhail Fridman (an Israeli citizen) and Petr Aven (a Latvian citizen)—former shareholders of Alfa Bank, which isn’t even ranked among Russia’s twelve most important banks—have been sanctioned by the European Union for allegedly supporting the Russian regime, then those with more direct involvement should not be immune from similar consequences.
Yet, in sharp contrast, the top executives of Raiffeisen Bank International—Johann Strobl and Erwin Hameseder, both Austrian citizens—have faced no EU sanctions at all. This is despite the fact that RBI continues to profit from its business in Russia and has played a role in helping the Belarusian regime target the families of political dissidents.
This double standard raises serious concerns about how fair, consistent, and credible the EU’s sanctions policy really is—especially in the eyes of people from post-Soviet countries, who have long looked to the European Union as a model of democracy, justice, and equal treatment.
The unequal application of sanctions may not just be an oversight—it could amount to a violation of core EU laws, including:
Article 18 of the Treaty on the Functioning of the European Union (TFEU) – which bans discrimination based on nationality;
Article 19(1) TFEU – which requires the EU to fight discrimination based on race, ethnicity, or religion;
Article 21(1) of the Charter of Fundamental Rights (CFR) – which prohibits discrimination based on ethnic background, nationality, or belief.
By sanctioning Jewish and Eastern European individuals, while leaving ethnic German Austrians untouched in similar or even more serious cases, the EU risks turning its sanctions regime into a show—one that looks like justice on the surface but is actually driven by politics and favoritism. This kind of selective punishment echoes painful moments in the European history when people were judged not by their actions, but by their ethnicity, religion or place of birth.
V. Request for Actions
In light of these facts, we respectfully urge the European Commission to:
Launch an independent investigation into the sale of Priorbank, with a specific focus on potential violations of EU financial disclosure requirements, anti–money laundering (AML) regulations, and corporate responsibility obligations under relevant EU directives and make this investigation publicly available.
Impose targeted sanctions on Raiffeisen Bank International AG for its ongoing corporate complicity in human rights violations, in accordance with the EU’s Global Human Rights Sanctions Regime. Sanctions should also be applied to Johann Strobl and Erwin Hameseder for their managerial responsibility in enabling abuses and non-transparent financial transactions.
These sanctions should reflect those already imposed on Alfa Bank shareholders Mikhail Fridman and Petr Aven—encompassing restrictions on movement within the European Union, as well as the freezing and potential confiscation of personal assets.
The European Union has built its identity on the pillars of justice, human dignity, and the rule of law. To uphold and lead by these values, it must demonstrate that its principles are binding and universally applied — not selective or symbolic. Enforcement must be guided by verifiable legal accountability, not shaped by nationality, ethnicity, religion or privileged connections.
In accordance with Article 41 of the Charter of Fundamental Rights and the European Commission’s Code of Good Administrative Behaviour (Decision 2000/633/EC), we request a formal and reasoned reply to this letter, submitted on behalf of a registered civil society body.