Russian nationals in Germany reported bank letters about sanctions risk and refusals at doctors' practices and restaurants; the federal anti-discrimination agency assessed the law.
Banks were contacting Russian customers to inform them of a possible sanctions risk, and of the possibility of averting it by proving a residence status. That was reported repeatedly to the advice team of the Antidiskriminierungsstelle des Bundes, Germany's federal anti-discrimination agency, alongside reports from Russian or Russian-descended people in Germany of hostility on Facebook, Twitter and Instagram. On 5 April 2022 the agency published a short item on those requests, headed "Anfragen russischer Staatsbuerger*innen", in the counseling-practice section of its newsletter issue 01/2022. The requests were coming in connection with the war in Ukraine, it said.
The agency said sanctions only come into consideration once deposits exceed 100,000 euro, and that customers with smaller deposits saw themselves placed under general suspicion by this approach. The measure at issue is Article 5b of Regulation (EU) 833/2014, inserted by Council Regulation (EU) 2022/328 of 25 February 2022. It bars accepting deposits exceeding 100,000 EUR per credit institution from Russian nationals or natural persons residing in Russia, and exempts nationals of a Member State and holders of a temporary or permanent residence permit in a Member State.
On the banks' conduct the agency reached no conclusion. Nationality is not a protected characteristic under the German General Equal Treatment Act (AGG), so a breach could arise only as indirect discrimination on grounds of ethnic origin. The decisive question, it said, was whether the practice was objectively justified, taking into account whether contacting customers in that form was necessary, for example to facilitate the handling of banking business or to avoid possible damages claims.
The agency said it had also received isolated inquiries about Russian nationals being refused access to goods and services, in particular access to doctors' practices and restaurants, and a refusal to sell furniture. On those refusals it went further. Direct discrimination on grounds of ethnic origin was conceivable, it said, where nationality is named as the ground of refusal but carries an ethnic attribution decisive for the less favorable treatment; indirect discrimination came into consideration otherwise, which requires that nationality be capable of particularly disadvantaging an ethnic origin.
Whether indirect discrimination requires a particular ethnicity to be adversely affected was, the agency said, not yet legally clarified; it cited the Court of Justice of the European Union judgment of 6 April 2017 in C-668/15 on country of birth, and added that particular effect on a specific ethnicity was rather unlikely in the case of nationality. It closed by saying that a reference to current political circumstances is not an adequate objective ground of justification, so that a refusal of goods and services would in the result likely be inadmissible.
Figures appear on the parliamentary record. Deutscher Bundestag Drucksache 20/1985 of 25 May 2022, the Federal Government's answer to a Kleine Anfrage by DIE LINKE (Drucksache 20/1719), states in answer to question 9 that since February 2022 a total of 196 advice-seekers with Russian and Belarusian roots had approached the agency feeling discriminated against because of their origin, nine of them concerning people of Belarusian origin. Of those advice requests, 74 concerned people who felt discriminated against by banks because of their Russian or Belarusian nationality, 18 concerned education, especially schools, and ten concerned discrimination in doctors' practices, hospitals or other medical facilities. The same answer records 16 people reporting discrimination on grounds of Ukrainian origin in the same period. The account is contested within that same document: asked in question 7 whether it knew of cases where people of Russian, Belarusian or Ukrainian origin were refused medical treatment or threatened with refusal, the Federal Government answered that no such cases were known to it.
The bank letters were also checked. A CORRECTIV Faktencheck of 14 March 2022 rated claims about letters Deutsche Bank and Postbank sent to Russian customers on 4 March 2022 as "Fehlender Kontext" (missing context). It confirmed with a Deutsche Bank spokesman that the letters were genuine, but recorded that the restrictions were balance limits arising from the 100,000 EUR threshold rather than general account freezes, that they did not apply to all Russian customers without an EU residence title, and that they could be lifted on production of a valid EU residence permit or EU citizenship.
The note gives no case numbers and names no businesses. The agency describes categories of inquiry rather than counted cases, calls the goods-and-services reports isolated instances, and does not say the accounts were verified or the complaints adjudicated. The underlying incidents are complaints made to its advice team, not facts the agency established or decided.
Sources
Where it stands
The page is still live and unretracted: fetched HTTP 200 on 5 September 2026 at the antidiskriminierungsstelle.gov.de address, carrying the headline and the date 05.04.2022 with no correction notice. The older antidiskriminierungsstelle.de host no longer serves the path, and no Internet Archive snapshot of the URL exists, so the current text cannot be compared with the 2022 original. It is a legal analysis, not a binding finding: it records no case, regulator decision or court ruling. On the banks it leaves the decisive question open, saying only that objective justification is what matters; on refusals of goods and services it goes further, saying a reference to current political circumstances is not an adequate justification and that such a refusal would likely be inadmissible.