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New restrictions on bank deposits of foreign creditors

New restrictions on bank deposits of foreign creditors

Presidential Decree No. 377 dated 1 June 2026 amended the temporary procedure for the discharge of obligations to certain foreign creditors established by Presidential Decree No. 95. The list of obligations subject to the special procedure now includes obligations under bank accounts and deposits, i.e. banks’ obligations to return deposits and pay interest to foreign creditors connected with “unfriendly” states.

Presidential Decree No. 95 sets a threshold of RUB 10 million for the execution of obligations without transferring funds to a special type “C” account. This threshold is calculated monthly based on the aggregate amount of the debtor’s obligations to all foreign creditors falling within Decree No. 95. In practice, the threshold will be assessed based on the total amount of the bank’s obligations to all such creditors and therefore will effectively have no practical significance.

In view of the above, when closing an account or deposit, as well as when paying interest, banks will be required to transfer funds to type “C” accounts regardless of the threshold. Funds held in such accounts may be used only for the permitted purposes, and withdrawal of funds from such accounts is possible only on the basis of permission from the Government Commission.

The foreign creditors with deposits in Russian banks primarily affected by these changes are:

Foreign companies from “unfriendly” states or companies controlled by them (except Russian companies);
Russian branches and representative offices of the above companies;
Individuals who are citizens of “unfriendly” states and do not have the status of Russian currency residents.

The changes do not affect foreign nationals holding a Russian residence permit or Russian companies whose participants or shareholders include persons from “unfriendly” states.

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04.06.2026

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