Bank Deposit Restrictions for “Unfriendly” Non-Residents: Scope and Application Clarified

Bank of Russia Clarification No. 1-OR of 14 July 2026 and Presidential Decree No. 550 of 4 August 2026 clarify how the restrictions under Presidential Decree No. 95 apply to bank deposits held by foreign creditors from “unfriendly” jurisdictions. Transactions that fall outside the Type C account rules may still be subject to other restrictions on transfers and foreign currency purchases.

Bank of Russia Clarification No. 1-OR: Current Accounts Are Not Subject to the Deposit Restrictions

Presidential Decree No. 377 of 1 June 2026 expanded Presidential Decree No. 95 of 5 March 2022 to include bank deposit obligations. Payments on covered obligations must be routed through Type C accounts. Some banks subsequently began applying the restrictions more broadly, including to current account transactions.

Bank Deposit Agreements and General Bank Accounts Are Treated Differently

Decree No. 377 applies only to bank deposit agreements. The special payment rules do not apply to general bank accounts, including correspondent accounts.

The Rules Apply Only When Payment Becomes Due

The special payment rules are not triggered when a deposit agreement is signed or renewed. They apply only when the bank is required to repay principal, pay interest, or both. Until then, the parties remain free to renew the deposit in accordance with general principles of Russian civil law.

The Monthly Threshold Applies Separately to Each Depositor

For purposes of paragraph 2 of Decree No. 95, the RUB 10 million monthly threshold is calculated separately for each depositor in each calendar month. It is not calculated across the bank’s entire deposit base.

Banks Cannot Reroute Payments to Avoid the Rules

Unless the Government Commission grants the approval required by paragraph 11 of Decree No. 95, a bank cannot satisfy a deposit obligation by transferring the funds to a non-Type C account or to an account held by a third party.

When the Special Payment Rules Apply

The special payment rules apply to a foreign creditor covered by Decree No. 95 only when all three of the following conditions are met:

  • the obligation arises under a bank deposit agreement rather than a general bank account
  • payment is due
  • the amount owed to that depositor exceeds the applicable threshold

If any one of these conditions is not met, the bank is not required to route the payment through a Type C account.

Presidential Decree No. 550: Prior Treatment Reinstated for Individuals and Branches

Presidential Decree No. 550 of 4 August 2026 removes individuals from “unfriendly” jurisdictions from the deposit restrictions. The same applies to Russian-registered branches, representative offices and other divisions of foreign creditor organizations.

The Decree reinstates the rules that applied before Decree No. 377 took effect. These creditors may receive in rubles funds credited to Type C accounts between 1 June and 4 August 2026.

Other Restrictions Remain in Place

The two measures do not change the broader restrictions on transfers and foreign currency purchases by “unfriendly” non-residents.

Transfers Outside Russia

Until 7 December 2026, individuals from “unfriendly” jurisdictions who do not work in Russia, as well as legal entities from those jurisdictions, may not transfer funds outside Russia. The restriction does not apply to foreign companies controlled by Russian individuals or legal entities. Non-resident individuals from “unfriendly” jurisdictions who work in Russia may transfer amounts up to the compensation payable under their contracts.

Foreign Currency Purchases

A decision of the Bank of Russia Board of Directors dated 19 July 2022, issued pursuant to paragraph 1 of Presidential Decree No. 126 of 18 March 2022, sets the foreign currency purchase limit for non-resident legal entities from “unfriendly” jurisdictions at zero. In effect, these entities may not buy foreign currency in Russia’s domestic foreign exchange market, except through conversion transactions involving Type “In” accounts.

Key contacts

Andrey Shpak

Partner, Head of Private clients

+7 963 673 0495 andrey.shpak@birchlegal.ru
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