After changing the list, there are a number of formal procedures that relate to interaction, including with individuals. For example, opening an account will most likely require more documents, if at all. Now there is no direct ban on opening accounts, but Russian citizens will experience even more significant difficulties with opening any account in any EU bank. Some will simply refuse to interact with the Russians in principle. We have faced this since the spring of 2022, and the situation has not changed for the better.
The formal procedure for Russian citizens will involve a more detailed check. Economic transactions with legal entities will also be subject to more thorough scrutiny, for example, when trading with countries from the “grey list”.
Any capital transactions from individuals and legal entities will also require more detailed verification, primarily in terms of the origin of capital.
In the current conditions, there are already much more stringent restrictions than getting into the "gray zone", for example, citizens and residents of Russia cannot have accounts, and, accordingly, conduct transactions for more than 100 thousand euros. Where are you from, who are you, what is the origin of this money, what documents are you ready to provide – no one will even study these questions.
Many EU banks perceive Russian clients as toxic and have the option of simply not opening accounts for Russians. And if this is not possible, then they are gently hinted that it would be good if they closed the account themselves.
The most unpleasant thing about all these formal decisions is that if the informal ones can quickly fade into the background with a conditional normalization of the situation, then the formal ones may not be canceled for quite a long time. Like the Jackson-Vanik amendment in the United States, which hung for decades. This is how it can take a long time.
In particular, because the EU is not united at all, and we see many different interests. Many decisions require compromises, and since economic interaction with Russia fades with varying degrees of intensity, depending on the sanctions or actions of one side or another, as a result, the EU may simply not have significant economic interests left to resume relations. The main threat is rather a medium-term and long-term horizon with a conditional normalization of the situation.