What's more is that the order to intensively scrutinize transactions merely based on an ethnicity and nationality is coming down on orders from top EU regulators. According to Reuters, "The instructions from ECB [European Central Bank] supervisors mean tens of thousands of Russians and Belarusians resident in the EU face intense surveillance by their banks, which are on alert for big payments and deposits as well as new credit applications, said sources."

The heaviest concentration of Russians in the EU are in Germany - at over 230,000 - and with Spain following, at more than 81,000. A source quoted in Reuters said, "At first, the measures were focused on those of Russian nationality, whether they were residents or non-residents, and later it was extended to Belarusians."

Lest anyone think this is just run-of-the-mill sanctions enforcement on Russian nationals and particularly that it's all about oligarchs, there's this glaring admission in the exclusive Reuters report that even EU residents could be under watch on the mere basis of their national origin: 

Some ECB supervisory teams, which include staff from the central bank and national authorities, have told banks to tighten control of EU residents too if they come from Russia or Belarus, said the sources, from banks and watchdogs.