Austria’s central bank will not take enforcement action against Raiffeisen Bank International (RBI) over allegations that a Russian subsidiary breached EU sanctions, documents published by the Austrian Ministry of Finance in early August have confirmed.

In a letter addressed to the President of Austria and responding to a parliamentary inquiry, Finance Minister Dr. Markus Marterbauer publicly confirmed that the Austrian National Bank (OeNB), the authority responsible for sanctions enforcement in Austria, had “investigated” the investment activities of Raiffeisen Management Company (formerly Raiffeisen Capital), a Russia-domiciled asset manager owned by RBI’s Russian subsidiary bank, and concluded that there was “no further need for action” against RBI.

Max Hammer, Human Rights Campaigner at BankTrack, said:
“This revelation is a serious setback in efforts to hold RBI accountable over its investments in sanctioned war bonds, in flagrant disregard for the EU’s financial policies towards Russia. All public evidence points to the fact that RBI did not take action to prevent its subsidiary from undermining EU sanctions on Russian bond investments. So we are deeply surprised by the Austrian National Bank’s decision and by the Finance Minister communicating it without any justification. We will be requesting that the OeNB explain and review its decision not to pursue action on this matter.” 

RBI’s Russian operations, which turned a higher profit than all other Western banks in Russia put together in 2024, came under renewed public scrutiny in March following an investigation by BankTrack and B4Ukraine.(1) The investigation revealed that RBI’s Russian asset manager had purchased bonds issued by Russia’s Ministry of Finance in late 2024, placing its parent company at risk of breaching EU sanctions-related prohibitions on Russian sovereign debt.(2) RBI has since repeatedly declined to provide detailed information on Raiffeisen Management Company’s activities to journalists, and all financial filings have been removed from the subsidiary’s website.

In response to the revelations, several members of the Austrian National Council submitted formal inquiries to the Austrian Finance Ministry, including Social Democratic Party MP Petra Bayr and Green Party MP Nina Tomaselli. Marterbauer’s August letter was issued in response to Bayr’s inquiry, which sought to ascertain whether the Austrian authorities had prior knowledge of Raiffeisen Management Company’s activities and whether any investigations were underway.

Though Marterbauer’s letter indicates that the OeNB has declined to take further action against RBI, the absence of a justification for the decision leaves important questions unresolved as to whether RBI indeed made the requisite efforts at preventing its subsidiary from undermining EU sanctions legislation and whether the bank has taken steps to address and rectify these activities.

Notes

(1)  Data derived from BankTrack’s Banks and Russia Tracker, updated in August 2025.

(2) Sanctions prohibiting EU companies from investing in Russian sovereign debt have been in place since early 2022. The Council of the EU extended this prohibition in August 2024 with a clause requiring EU companies to make “best efforts” to ensure their non-EU subsidiaries abide by the same restrictions.