5 December 2024
Subject: Request to Impose Sanctions on Raiffeisen Bank International (RBI)
The Honorable Ursula von der Leyen
President of the European Commission
The Honorable Roberta Metsola
President of the European Parliament
Members of the European Parliament
Dear President von der Leyen,
Dear President Metsola and esteemed Members of the European Parliament,
On behalf of the Belarus Democratic Forum, we urgently request that the European Commission take immediate action to impose sanctions on Raiffeisen Bank International (RBI), the only remaining major international financial institution continuing to profit from its operations in Russia and Belarus.
While the European Union has dedicated 92 billion euros and imposed extensive sanctions to support Ukraine’s sovereignty and democracy and to hold authoritarian regimes accountable, RBI’s continued presence in these markets undermines these efforts. Its operations not only sustain authoritarian regimes responsible for war crimes and systemic human rights abuses but also generate record profits. Russia alone accounts for more than half of RBI’s total earnings—far exceeding its profits from 12 European countries, including Germany, Poland, and Austria.
RBI’s operations make it function more like a Russian financial institution with Belarus as a subsidiary. While registered in Austria, the majority of its profits are generated in Russia and Belarus. This enables RBI to exploit its Austrian registration to evade the EU sanctions imposed on other financial institutions in these markets. By doing so, it undermines the EU's efforts to isolate authoritarian regimes and contributes to their economic and political sustainability.
RBI’s activities parallel historical examples of financial complicity during World War II, such as Swiss banks exploiting their neutrality to facilitate the Nazi regime. Neutrality or registration in an EU member state should not shield institutions from accountability for financing authoritarian regimes and undermining EU sanctions.
Grounds for Sanctions
Undermining EU Sanctions Policy
RBI’s continued operations in Russia and Belarus directly contravene the objectives of EU sanctions, which are designed to economically and politically isolate these regimes. Allowing RBI to operate freely undermines the credibility and effectiveness of EU sanctions.
Profiting from War Crimes and Repression
RBI’s profits in Russia and Belarus are generated from regimes responsible for war crimes in Ukraine and systemic human rights abuses in Belarus. This aligns with the conditions for imposing sanctions under the EU’s Global Human Rights Sanctions Regime.
Evasion of Accountability
RBI exploits its Austrian registration to avoid sanctions imposed on its competitors in Russia and Belarus. This creates an uneven playing field, undermines the EU’s principles of fairness and justice, and allows RBI executives and shareholders to profit without consequence.
Key Questions for Consideration
- Why has RBI been allowed to continue operations in Russia and Belarus while other financial institutions have faced sanctions and penalties for similar activities?
- Why have RBI executives and shareholders avoided sanctions, including asset freezes, despite profiting from activities that support authoritarian regimes?
- Should RBI face penalties for profiting from war crimes and repression, similar to the financial sanctions imposed on Swiss banks for their complicity during World War II?
Proposed Actions
- Freeze the Assets of Key RBI Executives and Shareholders: Sanctions should target those who directly profit from RBI’s operations in Russia and Belarus, including asset freezes and travel bans.
- Impose Financial Penalties on RBI: RBI should face substantial fines for its continued operations in these markets, sending a clear message that complicity in war crimes and repression will not be tolerated.
- Restrict RBI’s Access to EU Financial Markets: RBI’s ability to operate within the EU should be reassessed if it continues to undermine the EU's sanctions policies.
A Call for Justice
The European Commission has the tools and responsibility to ensure that no institution is above the law or allowed to profit from war and repression. By imposing sanctions on RBI, the EU would send a powerful message of accountability, strengthen its sanctions policy, and reaffirm its commitment to the principles of justice and human rights.
We urge you to act decisively to sanction Raiffeisen Bank International and its executives, ensuring that EU sanctions are applied uniformly and effectively. This is not only a matter of justice but also essential to safeguarding the resources and efforts the EU has dedicated to supporting Ukraine and Belarus in their fight for democracy and human rights.
Thank you for your attention to this urgent matter.
Sincerely,
Belarus Democratic Forum