European Union (EU) Sanctions on National Bank “TRUST” (NBT)

What Is NBT?

National Bank “TRUST”, commonly referred to as NBT, is a Russian state-owned bank.

It was created in 2018 after the Central Bank of Russia took control of several failed banks. NBT was given responsibility for managing and recovering their problematic loans and other non-core assets. ^[1]

Because of this role, NBT frequently appears in debt-recovery cases, insolvency proceedings, cross-border disputes, enforcement actions, and asset-recovery matters. The EU describes NBT as a state-owned bank that manages non-core assets and is majority-owned by the Central Bank of Russia. ^[1]

What Has the EU Done?

On 23 July 2026, the EU added NBT to its sanctions list. ^[2][4]

This means NBT’s funds and economic resources within the EU are frozen. EU persons and companies are generally prohibited from providing money, assets, or other economic benefits to the Bank. ^[1][2]

A further restriction applies from 13 August 2026. From that date, EU businesses and professionals will generally be prohibited from entering into transactions with NBT. ^[2]

Key Measures at a Glance

Can NBT Still Be Involved in Court Cases?

Yes. The sanctions do not automatically prevent NBT from bringing a legal claim or defending itself in court. ^[1]

However, the sanctions affect many financial arrangements connected to the case, potentially creating difficulties when NBT receives a settlement or damages award, legal costs must be paid, a creditor attempts to seize its assets, or an agreement is entered into with the Bank. ^[1][2]

The legal case may continue, but payments and transactions must be handled carefully.

Claims Brought by NBT

NBT may still bring or continue a claim in an EU court.

However, if NBT wins the case, any money payable to it cannot necessarily be transferred directly. ^[1]

This may include damages, settlement payments, recovered debts, legal costs, and enforcement proceeds.

The money may need to be paid into a frozen account or handled under an authorization from the relevant national authority. ^[1]

These payment arrangements should be considered before any settlement is signed.

Claims Against NBT

A person or company may also continue a claim against NBT and obtain a judgment.

The main difficulty is enforcing that judgment.

NBT’s EU assets are frozen, so a creditor may not be able to seize, sell, or transfer those assets without prior approval. ^[1]

This can make enforcement slower and more complicated.

Settlements and Payments

A settlement involving NBT may require sanctions approval before it can be completed. ^[1][2]

The agreement should clearly explain how payment will be made, where the funds will be held, whether a license is required, what will happen if approval is delayed, and which party is responsible for obtaining that approval.

A settlement should not be signed on the assumption that payment can be made in the usual way.

Legal and Professional Fees

Lawyers, insolvency practitioners, accountants, insurers, and litigation funders should also review how their fees will be paid.

Some legal fee exemptions may be available. However, they may still require approval from the relevant authority. ^[1]

Professional firms should confirm the position before accepting or transferring any payment connected to NBT.

The Transaction Ban

The transaction ban beginning on 13 August 2026 may be wider than the asset freeze. ^[2]

It may affect not only payments but also agreements entered with NBT, including settlement agreements, legal engagement letters, funding arrangements, cost-sharing agreements, contract amendments, and asset-recovery agreements. ^[2]

Each proposed arrangement should be reviewed before it is signed.

Different Rules in Different Countries

NBT’s sanctions status is not the same in every jurisdiction.

The European Union has designated the Bank, while the United Kingdom has maintained a different position. ^[2][4]

This means an activity may be allowed under one country’s rules but restricted under another.

Professionals should consider where the parties are based, where the assets are held, where the proceedings are taking place, which banks process the payments, which currency is used, and which country’s laws apply. ^[3]

Practical Steps

Professionals dealing with NBT or another sanctioned entity should:

1. Check the sanctions status of all parties.
2. Review the rules in every relevant jurisdiction.
3. Identify where the parties, assets, banks, and advisers are located.
4. Plan settlements, damages, costs, and legal-fee payments early.
5. Confirm whether a license or authorization is required.
6. Allow additional time for regulatory approval.
7. Continue monitoring sanctions throughout the case.
8. Keep written records of all checks, advice, and approvals.

The EU sanctions against NBT do not automatically stop legal proceedings involving the Bank. ^[1]

However, they significantly affect payments, settlements, legal fees, contracts, and enforcement actions. ^[1][2]

Any EU-connected person or organization dealing with NBT should carry out sanctions checks before making a payment, signing an agreement, or taking enforcement action. ^[1][2]

Sanctions compliance should be reviewed throughout the case, not only when the matter first begins. ^[3]

This article is for general informational purposes only and does not constitute legal advice.

References:

[1] https://eur-lex.europa.eu/eli/reg/2014/269?utm_source=chatgpt.com

[2] https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ%3AL_202601848&utm_source=chatgpt.com

[3] https://www.centralbank.ie/regulation/how-we-regulate/international-financial-sanctions/EU-restrictive-measures-relating-to-actions-in-Ukraine?utm_source=chatgpt.com

[4] https://www.reuters.com/business/finance/eu-ambassadors-agree-21st-sanctions-package-against-russia-eu-diplomats-say-2026-07-23/?utm_source=chatgpt.com