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Judgment of the Court in Case C-81/24 – The inclusion of a consumer on a US sanctions list is not enough to warrant a refusal to open a bank account.
A bank may refuse to open a basic payment account only after a case-by-case assessment of money laundering and terrorist financing risks.
In this case, a Slovenian bank relied on a customer’s inclusion on the US OFAC list, despite not being on EU/UN sanctions, in order to decide to not allow the consumer to open a payment account with basic features. The Court held that EU residents have a right to a basic account. This right can be restricted for the purposes of AML/CFT compliance. Being on an OFAC list alone does not justify refusal. It can, however, be considered as a factor when the bank is conducting its assessment on the consumer to decide whether it is too dangerous to allow the consumer to open a payment account. From that point, the refusal is lawful if the bank cannot adequately manage the assessed risk.
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Updated Commission FAQs
On 22 May 2026, the Commission published updated FAQs on tanker sales (Article 3q) and targeted vessels (Article 3s). On 06 May 2026, the Commission published updated FAQs on the movements of Russian diplomats (Art. 5v, 5w) and on the asset freeze and prohibition on providing funds or economic resources (Council Regulation (EU) No 269/2014).
Please scroll below to view the relevant FAQs.
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EU Sanctions Helpdesk: Free Webinar Series for Enhancing Compliance with EU Sanctions
The EU sanctions helpdesk is heading a four-part webinar series this May which is designed for anyone looking to develop an intermediate-level understanding of sanctions due diligence in practice.
What you’ll learn:
15 May – EU Sanctions Due Diligence in Practice Webinar: Module 1 – Counterparty Due Diligence
22 May – EU Sanctions Due Diligence in Practice Webinar: Module 2 – Restricted Products and Services
29 May – EU Sanctions Due Diligence in Practice Webinar: Module 3 – High-Risk Countries and Circumvention
5 June – EU Sanctions Due Diligence in Practice Webinar: Module 4 – End-Use and End-User Risks
