When I read on Monday morning that Luminor, a local bank operating in the Baltic states, is to be acquired by OTP, a company with a Hungarian background that operates not only in Central Europe but also in Russia, my first feeling was relief and satisfaction. Relief that I closed my Luminor account several years ago.

I just used it too rarely, and now I am fortunately spared moral dilemmas about how much my modest customer relationship with the bank might help Putin kill people in Ukraine.

In an ERR news story on Tuesday, the bank's communications manager Bence Gaspar commented that OTP is a very small bank in Russia (link in Estonian) — with a market share of 0.3–0.4 percent. "Our business there focuses on consumer loans for clients with lower creditworthiness, which is not such a sensitive activity. These are not business clients, and whatever we do, our first and most important goal is to comply with sanctions."

Kilvar Kessler, former long‑time head of the Financial Supervision Authority, says the bank's Russian presence should not be overstated, as there are other European banks still operating in Russia.

The easiest way to get an overview of OTP Bank's activities in Russia is probably to open the bank's Russian website at www.otpbank.ru. There, one does not get the impression that this is a microbusiness, as one might have been led to believe from the OTP spokesperson's comment.

On the front page, one learns that the bank has operated in Russia for 30 years, is one of the 50 largest banks in Russia, and has a presence in 800 Russian localities. OTP Bank issues consumer credit at 57,000 points in Russia and has two million active clients. "We help achieve goals" — one of OTP Bank's slogans for Russian clients.

"For those who are open to new things. We help clients unlock their potential and turn the boldest dreams into reality," people in Moscow, St. Petersburg, Tver and likely elsewhere can read.

According to the bank's comment, credits are not issued to business clients in Russia, but the information on the website advertises numerous other services for Russian small businesses and corporate clients.

Opening the small‑business section on the Hungarian‑Russian bank's website, one involuntarily gets the impression that Mr. Gaspar's modesty in presenting his employer would deserve a medal.

Because here it states specifically that OTP is one of the 30 largest banks in Russia (not 50) and has 2.4 million clients — almost twice the population of Estonia. Services offered by OTP include: current accounts, foreign trade, deposits, goods on installment, a recommendations program, and payroll projects. If you are a small company operating in a country at war for the fifth year, the idea of becoming a client of a nice foreign-owned bank might indeed arise.

For Russian corporate clients, OTP offers favorable conditions for currency transfers, letters of credit, and management of company cash flows.

If you are simply a private client of OTP Bank Russia, you have access to a debit card with 3,000 rubles cashback every month, a credit card (120 interest‑free days), and a cash loan ("up to 3 million rubles in three minutes").

At this point, a small question arises: how many people connected to Russia's armed forces, war industry or political repressive apparatus might have a convenient OTP Russia bank card or loan in their pocket? The website does not answer this, but it could be one of the questions asked by the European Central Bank as the regulatory authority whose task is to approve OTP's purchase of Luminor in Estonia.

Of course, it would be rather strange if a bank already operating smoothly in several EU member states suddenly did not receive permission to acquire a local bank in the Baltic states. Hard to imagine such a thing happening.

The publication The Banker wrote in May about the reasons why several European banks have not yet left Russia, as the U.S. Citibank did only this February, selling its branch to the Russian investment bank Renaissance Capital. One must find a suitable buyer for the Russian bank who is not under Western sanctions, and the transaction must receive approval from the Russian central bank and, in reality, also Vladimir Putin personally.

"French bank Société Générale sold its Russian subsidiary Rosbank at the start of the war in 2022, but other major lenders — UniCredit, Raiffeisen, ING — are still trapped in the country," notes The Banker.

Meaning, even if you want to leave, you are kept in Russia, if the parent bank is simply not ready to write off its billions in assets.

OTP Bank is not discussed separately in that story, but some stats are provided. The largest European bank subsidiary operating in Russia by assets is Austria's AO Raiffeisenbank with USD 24.1 billion. Next is Hungary's OTP Bank with USD 9.79 billion, followed by Italy's Unicredit Bank Russia with USD 8.4 billion (source: The Banker database, Q1 2026).

Of course, OTP is not Sberbank. But is not some marginal player in Russia running a small bakery under an archway. OTP Bank actively participates in the increasingly militarized Russian society. For example, OTP was present at this year's St. Petersburg International Economic Forum — the flagship event of the Russian economy and an international showcase, reportedly attended by 20,000 guests and featuring Putin himself. On the website one also finds a news story about the presentation by OTP Bank's head of the artificial intelligence lab, Alexey Mezentsev, at the GTM26 conference in St. Petersburg in July.

If you work in Russia, you will also help Moscow authorities develop the country's wartime economy and artificial intelligence — how could it be otherwise.

In any case, I remain pleased that I closed my Luminor account in time.

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