Quick answer: No, not unless you’re exempt. Since early 2022, EU law has capped deposits from Russian nationals and residents of Russia at €100,000 per bank, at every credit institution in the EU, including every bank in Portugal. But there’s a widely misunderstood exception: if you already hold an EU, EEA or Swiss nationality, or a valid temporary or permanent residence permit in one of those countries — including Portugal’s own D7, D8 or Golden Visa residence card — the cap does not apply to you at all.

This rule comes up constantly in relocation forums, usually in a garbled form (“Russians can’t have more than €100k in Europe” or “you lose your savings once you cross €100k”). Neither is quite right. The real rule, EU Council Regulation (EU) No 833/2014, Article 5b, is narrower and more workable than the rumor — and the residence-permit exemption is the part almost nobody mentions. This guide walks through exactly what the regulation says, who it applies to, and what it means practically if you’re moving to Portugal.

What EU Council Regulation 833/2014 actually restricts

Article 5b of Council Regulation (EU) No 833/2014 — the EU’s core sanctions instrument against Russia over the invasion of Ukraine — prohibits EU banks from accepting deposits above a combined total of €100,000 from:

  • Russian nationals,
  • natural persons residing in Russia (regardless of their nationality),
  • legal persons, entities or bodies established in Russia, and
  • legal persons, entities or bodies established outside the EU whose ownership is more than 50% Russian.

The rule is not a one-time transfer limit and it isn’t a tax. It’s a ceiling on the total deposit balance a covered person can hold at a single EU bank. The European Commission’s own FAQ on the measure, published to guide banks applying it, confirms this reading directly and is the clearest official explanation available in English.

Because it’s an EU regulation rather than a directive, Article 5b applies automatically in every member state, Portugal included, without needing a separate Portuguese law to bring it into force. Every bank operating in Portugal — Millennium bcp, Caixa Geral de Depósitos, Novo Banco, Santander Totta, ActivoBank and the rest — is legally required to enforce it.

The exemption almost nobody mentions

Here is the part that gets lost in translation on forums and social media: the €100,000 cap does not apply to everyone who happens to be a Russian citizen. Article 5b(3) carves out a clear exception for:

  • nationals of an EU member state, the European Economic Area, or Switzerland, and
  • natural persons who hold a temporary or permanent residence permit in an EU, EEA or Swiss state.

That second category is the important one for readers of this site. You do not need to give up your Russian passport or acquire a new nationality to escape the cap — you only need a valid residence permit somewhere in the EU/EEA/Switzerland. In practice, that means a Portuguese D7 visa residence card, a D8 digital-nomad residence card, a Golden Visa residence card, or any other valid Portuguese (or other EU/EEA/Swiss) residence title takes you out of the restriction entirely, from the moment it’s valid, regardless of how long you’ve held it or whether you’ve applied for citizenship.

This is confirmed directly by the same European Commission FAQ: dual holders of Russian nationality and an EU/EEA/Swiss nationality, and Russian nationals with a residence permit in one of those states, “can be credited above €100,000.”

Who exactly is covered — and who isn’t

A few scope questions come up repeatedly:

Does it matter where you live? No. The Commission has explicitly confirmed the prohibition “applies to deposits made by Russian nationals wherever they reside,” including Russian nationals living in a non-EU country such as the US, unless the exemption applies. Simply moving out of Russia to a third country doesn’t lift the cap by itself — only EU/EEA/Swiss nationality or residence does that.

Does it cover Belarusian citizens too? No. Article 5b is written specifically around Russian nationality and residence in Russia (plus majority-Russian-owned entities). Belarus is not named in the article, so the €100,000 deposit cap itself does not apply to Belarusian nationals. That said, banks apply their own enhanced due diligence to clients from any sanctioned or high-risk jurisdiction, so a Belarusian client may still face extra questions — that’s a bank compliance decision, not this specific EU rule.

Does it cover legal entities, not just individuals? Yes. The €100,000 ceiling applies per legal entity too, not on a consolidated group basis, and it also catches non-EU companies that are more than 50% owned, directly or indirectly, by Russian nationals or Russian residents.

How the cap actually works at a Portuguese bank

The mechanics matter more than the headline number:

SituationWhat happens
You’re opening a new account and are subject to the capThe bank cannot accept deposits that would push your total balance at that bank above €100,000
You already had more than €100,000 at a Portuguese bank before 26 February 2022That balance is grandfathered: you can keep it, spend it, or withdraw it, but the bank cannot let it grow back above €100,000
You already had less than €100,000You can add funds up to €100,000 at that bank, but not beyond it
You hold accounts at more than one EU bankThe €100,000 limit applies separately at each credit institution — it is not merged across banks

Two details worth flagging. First, the cap counts every account you hold at that bank together — current accounts, savings accounts, term deposits — not each account separately. Second, because the limit is set per credit institution rather than as an EU-wide aggregate, someone who is subject to the cap and has legitimate savings above €100,000 can, as a matter of law, spread them across separate banks, each staying under the individual-bank limit. Portuguese banks also carry reporting duties under a related article of the same regulation for any account they hold that is linked to a Russian national or Russian resident, so expect your bank to ask questions and request documentation regardless of your balance.

If you already have a Portuguese residence permit, the cap doesn’t apply to you

This is worth repeating because it’s the single most actionable fact in this article: if you hold a valid Portuguese residence permit — through a D7 visa, a D8 digital-nomad visa, a Golden Visa, or after a residence-permit renewal — Article 5b(3) already exempts you from the €100,000 cap. The exemption is triggered by the residence permit, not by naturalization, not by your NIF, and not by how long you’ve lived in Portugal.

This matters for sequencing. If your savings sit above €100,000 and you’re moving to Portugal on a D7 or D8 visa, the practical priority is getting your residence permit sorted — the cap stops applying to you the moment it’s valid, well before you’d ever be eligible to naturalize.

Opening or keeping a bank account as a Russian national in Portugal

The deposit cap is a ceiling on balance, not a rule about whether a bank has to serve you at all — but in 2026, Russian nationals in Portugal are facing more friction at account-opening and account-review stage than the regulation on its own would suggest. Two practical steps come before any of this:

  1. Get your NIF (Número de Identificação Fiscal). No Portuguese bank — traditional or digital — will open an account without one. See our step-by-step NIF guide if you haven’t got yours yet.
  2. Follow the standard account-opening checklist, which is the same regardless of nationality: passport, proof of address, proof of income, and (for Americans and increasingly for other nationalities) a tax self-certification. Our full guide to opening a Portuguese bank account covers the paperwork bank by bank.

One thing worth flagging plainly rather than glossing over: Ukrainian and independent press outlets (including The New Voice of Ukraine and UNITED24 Media) reported in June 2026 that Caixa Geral de Depósitos, Portugal’s largest state-owned bank, began notifying some Russian clients — reportedly concentrated among those without a valid Portuguese residence permit or with outdated identification on file — that their accounts would be closed by 14 August 2026. This has not been confirmed through an official CGD statement or a government notice, so treat it as a reported compliance decision by one bank rather than a change in EU or Portuguese law. If you bank with CGD, or are choosing a bank as a Russian national, the safest approach is to ask the bank directly, in writing, whether your account status is affected, and to make sure your residence permit, address and income documentation are current with them.

What if you genuinely need to exceed €100,000 for a specific purpose?

The regulation includes a separate, narrower mechanism for this: Article 5c allows a Member State’s competent national authority to authorise a bank to accept deposits above €100,000 in specific circumstances, such as funds strictly necessary to cover basic living needs (rent or mortgage payments, food, medicine, taxes, insurance premiums and utility bills), or for other defined official purposes. This is not automatic and not something you apply for directly as an individual: the credit institution itself has to request the authorisation on your behalf, and each request is assessed case by case by the competent authority, which can also impose reporting conditions. If this situation applies to you — for example, a specific, time-limited need tied to a property purchase or a documented living expense — ask your bank whether it is willing to submit that request, since the process and required evidence are set at the discretion of the national authority rather than spelled out in the regulation itself.

Common misunderstandings, corrected

  • “This is a Portuguese law, so maybe my bank interprets it differently.” No — it’s a directly applicable EU regulation. Every credit institution licensed in an EU member state applies the same €100,000 threshold and the same exemption; there is no Portugal-specific version of the rule.
  • “Once I get my NIF, I’m exempt.” No. A NIF is a tax number, not a residence permit, and it has no effect on the Article 5b cap. The exemption is tied specifically to EU/EEA/Swiss nationality or a residence permit.
  • “If I move out of Russia, the cap no longer applies to me.” Not by itself. The cap follows Russian nationality wherever the person lives; only the EU/EEA/Swiss nationality-or-residence exemption removes it.
  • “Belarusians face the same €100,000 cap.” Not under this article. Article 5b is written around Russian nationality and residence in Russia specifically.

Where to check for updates

EU sanctions on Russia have been expanded repeatedly since 2022, and it’s worth confirming you’re reading the current rule before making a decision based on it. The European Commission publishes and periodically updates its own plain-language FAQ on the deposit restriction, and the full, current consolidated legal text of Council Regulation (EU) No 833/2014 is maintained on EUR-Lex. Both are linked in the sources below. If your situation is financially significant — a large transfer, a request under Article 5c, or a bank threatening to close your account — confirm your specific case with the bank’s compliance department or a lawyer rather than relying on a summary, including this one.

The bottom line

The €100,000 figure is real, it’s EU-wide, and Portuguese banks are legally required to enforce it against Russian nationals and Russian residents. But it is not a wealth cap for anyone who happens to hold a Russian passport: the moment you have a valid EU, EEA or Swiss residence permit — Portuguese or otherwise — Article 5b(3) takes you out of the restriction completely. For Russians planning a move to Portugal with savings above €100,000, that makes the residence permit itself, not citizenship and not the NIF, the document that actually solves this problem.