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Knowledge, Lead article

What companies, banks and every individual can do

· Helfen statt Blockieren editorial team

A trader in Leipzig can do little about a law passed in Washington, Brussels or Moscow. Almost anyone can do something about the gap between “permitted” and “arrived”. An overview by role: what the law already offers today, what it costs and where it does not help.

Knowledge in seven steps: step 6

2 working daysuntil the EU Sanctions Helpdesk replies, according to the Commission, free of chargeEuropean Commission, 11 Jun 2025
30 daysdeadline for informing the Commission when US law listed in the Blocking Statute affects one’s interestsRegulation (EC) No 2271/96
§ 31German Payment Accounts Act: right to a basic account for consumers lawfully resident in the EUZKG
4.98%was the cost of sending 200 US dollars via money transfer operators, 13.40% via banksWorld Bank, Q4 2024

Companies

Many refusals happen because a bank cannot see quickly that a deal is permitted. A company can work on that.

  1. Check what actually applies. What counts are the EU lists and the goods lists, for dual-use items Regulation (EU) 2021/821. The EU Sanctions Helpdesk answers questions on EU sanctions free of charge; chambers of commerce and the bilateral chambers abroad advise on customs and exports.
  2. Talk before the first payment. A short message to the bank with invoice, description of goods, recipient and legal basis, always structured the same way. The proposal is described in “The trade file”.
  3. State the purpose of payment completely and truthfully. The file is meant to make permitted deals recognisable, not to make prohibited ones invisible.
  4. If refused, ask in writing for the reason: a legal obligation under EU law, or the bank’s own risk decision?
  5. Know the Blocking Statute. Anyone whose interests are affected by US law listed in its annex, for instance on Cuba or Iran, must inform the European Commission within 30 days. Anyone who has to deviate in an individual case applies for an authorisation.
  6. For goods to Russia and its neighbours, use the contract clause under Article 12g of Regulation (EU) No 833/2014 that prohibits re-export to Russia; the briefing on Russia sanctions in 2026 lists the checkpoints.

Limits: companies have no right to an account. The bank still decides for itself whom it accepts as a customer, and even the best file does little against the effect of foreign laws on banks. Payments in euros through banks without US dollar links have less contact with US law; it cannot be ruled out.

Banks

Banks have obligations against money laundering and terrorist financing, and sanctions violations are punished severely. The European Banking Authority therefore considers de-risking partly legitimate risk management and partly a sign of weak assessment. What it requires is clear:

  • Since October 2023, EBA guidelines require a bank to assess the risk of the individual customer before refusing, rather than excluding whole groups. For basic accounts they name milder means, such as limits on amounts and on transfers to third countries.
  • Since 9 January 2025, payment service providers in the euro area screen their customers at least daily against the EU sanctions lists. The EU lists are what count; whether a bank also applies US lists is its business decision.
  • For Cuba and Iran the Blocking Statute limits that decision: following the Bank Melli judgment, a termination without reasons shortly after a US listing may be invalid. Following judgment C-81/24 of 11 June 2026, a listing in a third country alone may not suffice to refuse a consumer a basic account.

Associations and chambers

Today every trader tells their case alone, and no authority counts refused permitted payments. In 2022 the EBA recommended that supervisors talk more with banks and affected customers. That requires figures. Helfen statt Blockieren proposes that chambers of commerce and associations collect cases anonymously in a uniform grid and present them in summary once a year: country, type of goods, type of obstacle, point in the chain, reason given, whether a ban applied, outcome. The grid is in “The trade file”; there is no sponsor for it yet.

Every individual

  • Account: anyone lawfully resident in the EU has a right to a basic account. In Germany, if a bank refuses, administrative proceedings can be requested at BaFin.
  • Sending money to family: costs vary widely. At the end of 2024, sending 200 US dollars cost on global average 13.40 percent via banks and 4.98 percent via money transfer operators. Which routes into a given country are open changes; for Cuba, Western Union stopped transfers again in February 2025.
  • Donating: the three aid organisations of the week collect for microcredits, the Loyola centres and a solar system for a children’s hospital in Havana; donations go directly to them (aid organisations of the week). Separately, a fundraiser covers the costs of the week; it is not a donation and does not go to Cuba.
  • Goods in kind: medicines only through aid organisations that export them lawfully. For the planned aid in kind with wheelchairs and food, Helfen statt Blockieren screens donors and recipients against the EU financial sanctions lists before every acceptance and every shipment.
  • Understand and take part: the online workshops from 16 to 19 November cover the Blocking Statute, over-compliance and permitted deliveries; next year’s case is decided by a vote, one vote per person. Please report errors on this website.

What is being debated in politics

The editorial team does not recommend a political line. It records what is disputed. The Blocking Statute is rarely enforced; a Commission consultation on reforming it ran in 2021, and no legislative proposal appears in the sources read. After new US sanctions against the International Criminal Court, 58 members of the European Parliament called in October 2026 for it to be applied; the Commission is relying on dialogue for now. On Cuba, Parliament demanded on 18 June 2026 the release of all political prisoners, far-reaching reforms and more aid against the humanitarian crisis. In the UN vote on 28 October 2026, ten EU states abstained, Germany among them, and four voted against. Which of this is right is not for this website to decide.

What nobody can solve alone

The US embargo is decided in Washington; the obstacles inside the country and the detention of political prisoners in Havana. No file and no donation changes that. They do narrow the gap in which permitted goods are lost, and that is exactly where the week comes in.

This lead article is information, not legal advice. It reflects the view of the editorial team and relies on the sources listed and the linked building blocks. “Helfen statt Blockieren” is non-partisan.

Sources

All online sources accessed on 3 November 2026.

All seven steps