Deposits held by foreign nationals in Russia from 1 June 2026 onwards: Bank of Russia’s official clarification

KEY TAKEAWAYS

• In its July clarification, the Bank of Russia confirmed that the new regulation does not apply to ordinary bank account agreements with foreign creditors, including correspondent account agreements. The operation of Decree No. 95 is therefore limited to bank deposit agreements only. It should be noted that, for complex interest-bearing savings products, focus should be on the legal substance of the arrangement, rather than its commercial label. For example, a savings account may, under certain circumstances, be legally classified as a deposit.

• The fulfillment of obligations under a bank deposit agreement includes both the repayment of the principal amount and the payment of accrued interest. Accordingly, the temporary procedure may apply to both principal and interest payments when they become due. The regulator has clarified that Decree No. 95 prohibits the transfer of funds under a bank deposit agreement to accounts other than the foreign creditor’s Type C account, as well as the transfer of a deposit to a third party’s bank account without obtaining special authorization. It remains an open question whether funds held under such deposits may be subject to direct debit arrangements, or third-party claims may be enforced against such deposits before their maturity date.

• The Bank of Russia indicated that a bank deposit agreement may be renewed in accordance with the Russian Civil Code. In this case, the deposit amount and accrued interest do not need to be transferred to a special Type C account. However, if the deposit agreement provides for periodic interest payments, such payments will still be made through a special account. 

• The Bank of Russia emphasized that the temporary procedure for fulfilling obligations to foreign creditors does not apply until the bank’s obligation to repay the deposit amount and accrued interest actually becomes due.

• The regulator clarified that the RUB 10 million threshold (including the deposit amount and accrued interest) applies separately to each foreign creditor on a calendar month basis. Previously, a more conservative approach had been considered, requiring that the threshold be calculated in aggregate for all creditors of the bank. The regulator has now confirmed a more liberal approach.