Grizzly Research, an investment company that specializes in short selling, said Russian customs records from 2022 through early 2025 contain more than 25,000 contracts worth a combined $1.75 billion that list the Bank of Russia registration number of AO Raiffeisenbank.
Of those, nearly 19,700 records worth $1.191 billion involved goods covered by restrictions imposed by the EU, the United States, Britain or Switzerland, according to Grizzly's calculations. A further $106.75 million covered "high-priority" goods — Western-made items deemed critical to the Russian armed forces, the researchers wrote.
The supply records cited by Grizzly mention CNC lathes, bearings, integrated circuits, switches and routers. Citing Ukrainian analysts, the fund said the Russian defense industry consumes 70-80% of CNC machine tools, with the equipment procured mainly by AMG, a company added to U.S. sanctions lists in November 2023 and EU lists in December 2024.
A separate check of the database by counterparties identified transactions worth $49 million involving at least 33 companies that were already subject to sanctions at the time. Grizzly also claims that trade operations with Iran and North Korea using Raiffeisenbank's banking code exceed $10 million.
Part of the investigation is based on Grizzly employees posing as potential clients in conversations with bank managers. In one case, the investor wrote to a manager that his company planned to buy Ubiquiti networking equipment in the United States, part of which would be sold in Russia "for the needs of the SMO," with the rest sent to Iran. According to the published correspondence, the manager agreed, noting that on Iran the bank has "only one restriction — we don't send them euros."
In another experiment, Grizzly staff posed as a charitable foundation buying drones for the war. Several employees replied that this would not prevent an account from being opened, and one manager gave approval after a supervisor signed off. The foundation was reserved account details for 14 days before the formal opening.
A consultant who helps Russians transfer money abroad told Grizzly that the scale of Raiffeisen's Russian business has grown too large for effective oversight: transactions of less than $1 million cannot be properly checked because of their volume. The same source claims a bank manager allegedly advised a client to replace a sanctioned HS commodity code in documents with a code not covered by restrictions.
The fund itself acknowledges that the customs records it examined do not by themselves prove that payments were made for those deals, or that financing, income or even a sanctions violation occurred. Grizzly has opened a short position on RBI shares and intends to profit from a fall in their price.
Raiffeisen Bank International rejected the accusations. Bank spokesman Rupert Reif told Reuters that RBI is confident in the reliability of its compliance systems, which have been repeatedly reviewed before and after the start of the war, and that a preliminary analysis of the report found a number of factually incorrect and misleading statements. He did not specify which.
Bloomberg Intelligence analysts Tomasz Noetzel and Ilya Shchupko noted that the Grizzly report may exaggerate sanctions risks. In their view, the fact that trade operations were linked to RBI's Russian subsidiary does not indicate a sanctions violation. They see a greater threat in possible increased scrutiny from regulators — an additional review by OFAC or the ECB could increase the discount applied to the valuation of the Russian business and complicate RBI's exit from Russia.
Raiffeisen remains one of the last Western banks still operating in Russia. RBI has repeatedly stated its intention to wind down its business in the country, but, as Bloomberg notes, the Russian authorities have created almost insurmountable obstacles: the Kremlin regards Raiffeisenbank as an important channel for cross-border settlements in Western currencies. Grizzly claims that RBI reports 700 million euros of funds blocked in Russia, whereas the actual figure exceeds 12 billion euros.
After the report was published, RBI shares fell by almost 10% at one point.