Construction · Hungary · Sanctions-compliance burden

Every Paks II invoice triggers an EU sanctions filing. Hungarian subcontractors wait months to be paid.

Russia's Paks II nuclear expansion is the only EU public-works project that depends on Article 12h of EU Regulation 833/2014 — a narrow sanctions carve-out that lets the work continue only if every Russian-side transaction is notified to the Hungarian authority before money moves. Stack that on a US Treasury designation of Gazprombank (the bank that holds Paks II's performance guarantee), a Hungarian client that has frozen every payment since November 2024 to protect itself, and three Gazprombank general licences re-scoped in fourteen months. The result: small Hungarian firms doing structural concrete, excavation, engineering services and workers'-hostel operation sit on months of unpaid invoices, all undisputed, all stuck.

TL;DR

What hurts Hungarian subcontractors at the Paks II nuclear expansion must clear every invoice through an EU sanctions notification (Article 12h of Regulation 833/2014) — and the Hungarian state-owned client has not approved a single payment since the US sanctioned the Russian bank that funds the project in November 2024.
How big One workers'-hostel operator near the site is owed about €100,000; Direkt36's June 2025 investigation confirmed multiple unpaid field-works subcontractors at Paks II, with payments frozen since end-2024.
Why startups win Sell a Hungarian-language compliance desk that files the EU pre-transaction notice for every subcontractor invoice, screens the counterparty against EU and US sanctions lists, and tracks each Gazprombank general licence by expiry date — a recurring per-invoice fee on roughly 400 active Paks II suppliers. 5 self-marketing global sanctions-screening vendors cataloged below — none today productises the Article 12h notification, which is the wedge.

01The pain

A workers' hostel near Paks II is owed about €100,000 for beds, meals and laundry delivered to Rosatom subcontractors months ago. The owner told a Hungarian nuclear-industry expert his money has been stuck since the Hungarian state stopped approving Paks payments at the end of 2024.¹

The choke-point is regulatory. Paks II is the only Rosatom-built reactor inside the European Union, and the only EU public-works project that survives on Article 12h of EU Regulation 833/2014 (the sanctions code), which permits transactions with Russian state entities only if a pre-transaction notice is filed with the host country's authority first.² The US Treasury's Office of Foreign Assets Control (OFAC, the arm that runs US sanctions) then placed Gazprombank, the bank that holds the project's performance guarantee, on its sanctions list in November 2024. The Hungarian client Paks II Ltd. froze every payment to avoid secondary sanctions on itself.¹

OFAC has since issued, re-scoped and let expire three Gazprombank general licences (case-by-case carve-outs); none wide enough to release the back-arrears.² Rosatom has anonymised its Paks tender documents since 2023; winners appear as "Bidder 4", so Hungarian sub-subcontractors cannot see who they invoice through.¹ Foreign Minister Péter Szijjártó conceded in February 2025 that the sanctions "make it more difficult for the Paks project to progress".³ The firms that did the work in 2024 are still waiting.

About €100,000 owed to one workers' hostel — invoiced, undisputed, stuck since 2024.¹

"Several of Rosatom's subcontractors, including the companies performing field works at the Paks site, submitted their invoices for the work performed, but they did not receive their payment." — Direkt36 investigation, "How US sanctions broke Paks II," 3 June 2025, quoting a source with close knowledge of the project.

02Who solves this today

Five established global sanctions-screening and risk-intelligence platforms publicly market the closest products to the Paks II subcontractor's Article 12h notification problem (counterparty screening against EU and OFAC sanctions lists, general-licence monitoring, transaction-level workflow). None today markets a productised Hungarian-language Article 12h pre-transaction notification service tied to a Gazprombank general-licence tracker — that absence is the wedge. Each entry was checked live on the date of writing.

ComplyAdvantage

London-headquartered financial-crime risk platform. Markets sanctions and watchlist screening, customer and company screening, ongoing monitoring, transaction monitoring, payment screening, and adverse-media checks. No Hungarian-language Article 12h notification product surface published; the sanctions-screening product covers EU/OFAC list checking as a building block.

complyadvantage.com

LSEG World-Check

London Stock Exchange Group's KYC (know-your-customer) and sanctions-screening database. Markets World-Check risk intelligence, the World-Check On Demand API, and structured machine-readable risk data covering global sanctions and politically-exposed-persons (PEP) lists. Used by global banks for sanctions screening; no Paks-II-specific surface.

lseg.com/en/risk-intelligence

Dow Jones Risk & Compliance

Dow Jones's risk-intelligence arm. Markets sanctions, PEP and adverse-media data, third-party risk management, anti-bribery checks, and a Risk Center workflow tool. Maintains Hungarian-language site coverage for editorial content; no productised Article 12h notification surface.

dowjones.com/professional/risk

Moody's Sanctions360

Moody's KYC and compliance platform. Markets Sanctions360, Grid for Screening, Orbis for Compliance (ultimate-beneficial-owner mapping), Maxsight investigations, and a Perpetual KYC workflow. Strong on entity-level due diligence and beneficial-ownership unwinding for sanctioned counterparties.

moodys.com/web/en/us/kyc.html

sanctions.io

Berlin-based sanctions-screening API. Markets a Screening API, Batch Screening API, Manual Screening Portal and Continuous Monitoring against sanctions lists, PEP data, criminal watchlists and adverse-media data, with native integrations into SAP, Salesforce, HubSpot and BigID. API-first pricing more accessible to SME-scale buyers than the incumbent platforms.

sanctions.io

Listed providers publicly market to the global sanctions-screening, KYC and risk-intelligence niches on their own homepage or service pages. Inclusion is not endorsement. Honest gap-note: no Hungarian-headquartered or Hungarian-language vendor publicly markets a productised Article 12h pre-transaction notification + Gazprombank licence-tracking service tailored to Paks II subcontractors — the niche is open. Probed and dropped (verbatim audit log so the editorial reasoning is auditable): LexisNexis Risk Solutions's published Bridger Insight XG product URL and the broader financial-crime-compliance product URL returned HTTP 403 responses on probe (anti-bot protection), so the vendor is not listed despite a self-marketed sanctions-screening product surface; Napier AI's published sanctions-screening URL returned an HTTP 404; a probe of a candidate Hungarian compliance domain (kompliance.hu) returned a DNS resolution failure. Paks II Ltd., Rosatom, Titan-2 and Orgenergosztroj are referenced in section 01 as the contracting parties whose dispute creates the pain rather than as solution providers; the US Treasury Office of Foreign Assets Control (OFAC) and the European Commission are the licensing and regulatory authorities for any compliant payment route and are referenced as such. Direkt36, Telex, HVG, Index.hu, OSW (Centre for Eastern Studies, Warsaw) and Portfolio.hu are referenced as media citations and as the community-evidence venue rather than listed as solution providers.

Operators discussing this

These are real Hungarian operators and observers talking about this pain in their own words. They are the reason this page exists.

«Érdekes Gazdasági lépés ez a Paksi Atomerőmű. Jó lenne, ha itt lehetne gyüjteni a dolgokat, információkat róla. Szakmai, műszaki, gazdasági szempontból elkezdett érdekelni a téma.»

"Paks is an interesting economic move. It would be good to collect things and information about it here. I've started taking an interest in the subject from a technical, engineering and economic standpoint."

Paksi Atomerőmű, Paks II. — Portfolio.hu fórum (topiknyitó: Hathor) — Active multi-year operator/observer thread opened 2 April 2016; the same topic remains the main Paks II discussion hub on Hungary's largest finance forum, with continued posts through 2025-2026 as each new sanctions / OFAC / Gazprombank turn lands.

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