Ban on the export of banknotes in all official EU currencies to Russia and Belarus

Under Article 5i(1) of Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine, it is prohibited to sell, supply, transfer or export banknotes denominated in any official currency of an EU Member State to Russia or to any natural or legal person, entity or body in Russia, including the Government of Russia and the Central Bank of Russia, or for use in Russia.

The prohibition applies to:

• euro banknotes
• banknotes of other official currencies of EU Member States

Exemption for personal use

The exemption is laid down in point (a) of Article 5i(2) of Regulation (EU) No 833/2014. The prohibition does not apply where the sale, supply, transfer or export of banknotes is necessary for:

• the personal use of a natural person travelling to Russia
• the personal use of that person's immediate family members travelling with them

This is a narrowly applied exemption to the general prohibition, not a general right to take a chosen amount of euro banknotes or banknotes of other official currencies of EU Member States to Russia.

The legislation does not set a specific amount of banknotes that would be considered permissible in all cases. Whether the exemption applies is assessed individually in each case, taking into account the circumstances of the journey, the purpose for which the banknotes are to be used, and the explanations and evidence provided by the traveller.

What “personal use” means

In its judgment of 30 April 2025 in Case C-246/24, the Court of Justice of the European Union clarified the concept of “personal use” as used in point (a) of Article 5i(2) of Regulation (EU) No 833/2014.

According to that clarification, the banknotes must be necessary for the personal needs of the natural person travelling to Russia, or of the immediate family members travelling with them, directly connected with their journey and stay in Russia.

The mere fact that the banknotes belong to the traveller, or that the traveller intends to use them for their own expenses, does not in itself mean that the exemption for personal use applies.

When the exemption does not apply

The exemption for personal use does not cover banknotes intended for:

• professional or commercial activity, including business trip expenses or per diem allowances
• investment purposes
• the acquisition of immovable property
• the servicing of a mortgage loan or another long-term financial obligation
• transfer to another natural or legal person in Russia
• payment for planned medical or treatment services in Russia
• other purposes not directly connected with the needs of the traveller's journey and stay in Russia, or those of their immediate family members travelling with them

The traveller's obligation to substantiate the application of the exemption

A traveller relying on the exemption for personal use must substantiate to the customs officer that:

• the banknotes are necessary for their own personal needs or those of the immediate family members travelling with them
• those needs are directly connected with the journey and stay in Russia
• the banknotes will not be used for professional, commercial or investment purposes
• the amount carried does not exceed what is objectively necessary for the needs of that specific journey and stay in Russia

The customs officer may ask the traveller to explain:

• the purpose for which the banknotes are being taken out
• the specific goods or services for which they will be used
• which expenses of the journey or stay in Russia cannot be covered by other means of payment
• how the amount of banknotes being taken out was calculated

Substantiating the necessity of the banknotes and their intended personal use is the traveller's obligation.

Important. The mere fact that the banknotes belong to the traveller or are intended for their personal expenses does not in itself mean that they fall within the exemption laid down in point (a) of Article 5i(2) of Regulation (EU) No 833/2014.

Where a journey to Russia is planned in advance, the traveller should arrange suitable means of payment in advance and should not carry euro banknotes or banknotes of other official currencies of EU Member States if their necessity for that specific journey cannot be substantiated. In such a case, it is recommended to choose in advance a currency whose banknotes are not subject to the export prohibition laid down in Article 5i of Regulation (EU) No 833/2014.

The mere fact that it would be more convenient for the traveller to pay in euro is not grounds for applying the exemption laid down for personal use.

What additional documents need to be submitted to the customs post officer

Regulation (EU) No 833/2014 and the legislation implementing it do not set out an exhaustive list of documents that a person must submit in order to rely on the exemption laid down in point (a) of Article 5i(2).

The person must substantiate that this exemption can apply in their case. Taking into account the specific circumstances of the journey, they must provide sufficient and reliable evidence enabling customs officers to be satisfied that the banknotes being exported are necessary for the personal use of the person and of the immediate family members travelling with them, during the journey and stay in Russia.

The documents submitted must be:

• authentic
• drawn up in a comprehensible language, preferably Lithuanian
• directly substantiating the necessity of the banknotes and the specific exceptional circumstances

The nature of the documents may vary depending on the specific situation. They may include, for example:

• a travel itinerary
• travel and accommodation bookings
• insurance documents
• explanations and calculations of anticipated expenses
• other documents or evidence substantiating the necessity of the banknotes

The customs officer assesses individually, in each case, whether the information and documents submitted are sufficient to apply the exemption from the prohibition on exporting euro banknotes or banknotes of other official currencies of EU Member States.

In what form the information must be submitted

Under Article 135 of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union Customs Code, and Articles 135–142 of Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No 952/2013 of the European Parliament and of the Council with detailed rules concerning certain provisions of the Union Customs Code, goods subject to prohibitions or restrictions may not be declared orally or by any other act.

In view of this, banknotes being carried must be declared to the customs officer by submitting:

• a passenger declaration
• documents, information or other evidence substantiating the application of the exemption laid down for personal use

Detailed information on the declaration of cash can be found in the section Bringing cash into and out of the country.

An equivalent prohibition on the export of banknotes also applies when travelling to Belarus.

Under Article 1za of Council Regulation (EC) No 765/2006, it is prohibited to sell, supply, transfer or export euro banknotes and banknotes of other official currencies of EU Member States to Belarus, to persons, entities or bodies in Belarus, or for use in Belarus.

The prohibition does not apply where the banknotes are necessary for the personal use of a natural person travelling to Belarus, or of the immediate family members travelling with them. The Regulation also lays down other specific exemptions.

The exemption for personal use when travelling to Belarus applies on the basis of the same principles described above for travel to Russia. No specific amount of banknotes permitted in all cases is set. The person must substantiate that the banknotes being taken out are necessary for their own personal needs, or those of the immediate family members travelling with them, during the journey and stay in Belarus, and must provide information, documents or other evidence to substantiate this.

Where the application of the exemption is not substantiated, the prohibition applies to the export of the banknotes.

When planning a journey to Belarus in advance, as with Russia, it is recommended to arrange other suitable means of payment or a currency to which this prohibition does not apply.

• Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine
• Council Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine
• Judgment of the Court of Justice of the European Union of 30 April 2025 in Case C-246/24 https://eur-lex.europa.eu/legal-content/LT/TXT/?uri=CELEX:62024CJ0246