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Explained: why a permitted payment gets stuck

· Helfen statt Blockieren editorial team

The invoice has been paid, but the money does not arrive. Often there is no prohibition behind it, but a check that raises an alert, or a bank that would rather refuse than examine. This is the path of a payment and of a shipment through sanctions screening, and these are the points where it stalls.

Two paths that belong together

A cross-border deal has two paths: that of the goods and that of the money. Both pass through checks. Some are mandatory because the EU or the United Nations have adopted sanctions. Others rest on a bank’s business policy. To the trader both look the same: nothing moves.

The path of a payment

Five stations, three typical stopping points. Tap or tab to a box for details.

1Orderthe trader releasesthe transferAccount closedthe bank ends therelationship:de-risking2Own bankchecks names, countryand the customer’sriskSimilar namea hit that is no hit:questions, delay3Correspondentonly for foreigncurrency or withouta direct linkForeign lawdollar bank refusesunder a US list4Payee’s bankchecks again underits own law5Payeethe money arrives1Orderthe trader releasesthe transferAccount closedthe bank ends therelationship:de-risking2Own bankchecks names, countryand the customer’sriskSimilar namea hit that is no hit:questions, delay3Correspondentonly for foreigncurrency or withouta direct linkForeign lawdollar bank refusesunder a US list4Payee’s bankchecks again underits own law5Payeethe money arrives

Sketch: Helfen statt Blockieren, based on EBA (2022) and Deutsche Bundesbank (FAQ on financial sanctions, June 2026).

What is mandatory

EU financial sanctions prohibit making funds available to listed persons and companies. In Germany, the Deutsche Bundesbank implements these sanctions where funds are concerned. Its Financial Sanctions Service Centre in Munich receives reports and grants exemptions where a regulation provides for them. For goods, services and investment, the Federal Office for Economic Affairs and Export Control (BAFA) is responsible.

What is caution

In 2022 the European Banking Authority (EBA) examined whom banks in the EU turn away. It found de-risking across the EU. Those affected include payment and e-money institutions, non-profit organisations, asylum seekers from high-risk countries and cash-intensive businesses; the report names car dealers, hairdressers and coffee shops as examples. Banks with dollar clearing said they cannot deal with persons and companies on US sanctions lists, even where these lists differ from those of the EU or the UN.

The EBA is clear: refusing a whole group of customers without assessing the risk of the individual customer is unwarranted de-risking. It can be a sign of poor risk management and can breach consumers’ right to a basic payment account. Since October 2023 EBA guidelines have set out what a bank must do before refusing a customer. For basic accounts they list less restrictive options, such as limits on amounts and on transfers to third countries.

A difference that matters

In Germany, consumers legally resident in the EU are entitled to a basic account (section 31 of the Payment Accounts Act). If a bank refuses, they can ask the financial supervisor BaFin to open administrative proceedings (section 48). Companies have no such entitlement. A trader whose account is closed has to find another bank.

The second path: the goods

Before money flows, the goods must be allowed to leave. The check follows six questions. Dual-use items are governed by Regulation (EU) 2021/821. For goods to Russia, Article 12g of Regulation (EU) No 833/2014 has required, since 20 March 2024 and for certain goods, a contract clause prohibiting re-export to Russia; partner countries such as the US, Japan, the United Kingdom and Switzerland are exempt.

The path of a shipment through screening

Six questions before export. Red marks where a deal can stop.

1Goodstariff code andtechnical data2Control listdual-use Annex Iand sanctionsannexesLicenceapply to BAFA;a list ruling ispossible3Countryis there an embargoor a limit for thedestination?Banno shipment wherea ban applies4Recipientname, owners andend user checkedagainst EU listsListednothing for listedpersons5End useany sign of amilitary end use?6Exportcustoms declaration,with a licencewhere needed1Goodstariff code andtechnical data2Control listdual-use Annex Iand sanctionsannexesLicenceapply to BAFA;a list ruling ispossible3Countryis there an embargoor a limit for thedestination?Banno shipment wherea ban applies4Recipientname, owners andend user checkedagainst EU listsListednothing for listedpersons5End useany sign of amilitary end use?6Exportcustoms declaration,with a licencewhere needed

Sketch: Helfen statt Blockieren, based on Regulation (EU) 2021/821, Regulation (EU) No 833/2014 and GTAI.

Where it most often stalls

  • A name resembles a listed name, and the bank lacks the details to rule it out.
  • The payment reference mentions a country or a word that triggers a filter, although there is no prohibition.
  • The payment is in US dollars and therefore runs through a bank that follows US law.
  • The bank does not assess the individual deal but has decided to stop doing business with a country or sector altogether.

What this looks like for Cuba, where the US embargo and the failures of the Cuban leadership, up to and including political prisoners, come together, is described in the piece “Cuba’s private firms”. What traders can do in advance is set out in the proposal “The trade file”.

Help that costs nothing

The European Commission runs the EU Sanctions Helpdesk for companies, especially small and medium-sized ones. On request it checks whether a deal falls under EU sanctions, answers within two working days according to the Commission, and all its services are free.

This piece is information, not legal advice. It reflects the author’s view. “Helfen statt Blockieren” is non-partisan.

Sources

All online sources accessed on 3 November 2026.

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