Regulatory updates on foreign individuals’ deposits in Russia effective 1 June 2026: legal uncertainties and risks

On 1 June 2026, the President of the Russian Federation signed Decree No. 377, which extends the scope of Decree No. 95 dated 5 March 2022 (“On the Temporary Procedure for Fulfilling Obligations to Certain Foreign Creditors”) to bank deposits. Decree No. 377 took effect on the date of its signing.

For context, Decree No. 95 of 2022 introduced the concept of “foreign creditors”. They include individuals and legal entities associated with foreign states involved in unfriendly activity towards Russia[1] — identified by virtue of nationality, place of registration, principal place of business or primary source of profit — as well as any persons under their control, irrespective of place of registration, excluding the Russian Federation[2].   

Russian debtors must follow a specific procedure when fulfilling obligations to this category of creditors. If monthly obligations exceed RUB 10 million, the debtor (e.g., a bank) is required to open a special Type C account in Russian rubles for the creditor, to which the performance amount would be transferred. Russian currency residents, specifically Russian citizens and foreign nationals holding a Russian residence permit, do not qualify as foreign creditors[3].

As of the date of this review, the Bank of Russia has not issued any clarifications on the application of Decree No. 377. Therefore, the practical implementation of the new regulations creates some uncertainty.

There is ambiguity in how the RUB 10 million threshold applies. It could be interpreted either as total payments made by a single debtor (e.g., a bank) to all “unfriendly” creditors or as a per-creditor limit. As of now, we understand that banks have adopted a conservative approach, favoring the first interpretation. Given the absence of specific guidance, banks are likely to apply Decree No. 377 in a conservative manner.

Theoretically, there is a risk that the conservative approach could extend to interest-bearing deposits; however, no such precedents have been observed so far.

Where funds are transferred to a Type C account, only the following transactions are permitted:

• Acquisition of federal loan bonds (at initial issuance only)
• Payment of taxes, duties, fees and other mandatory contributions to the Russian federal budget (only for obligations of the account holder)
• Transfers to other Type C accounts opened for the same or another non-resident (e.g., for the acquisition of foreign securities, where permitted)
• Transfers to RUB-denominated accounts of non-residents – only with a special permit from the Ministry of Finance of the Russian Federation (in practice, such permits are not granted)
• Payment of bank fees for account servicing
• Reversal of erroneously credited funds[4]

Compulsory enforcement against funds in Type C accounts for obligations to third parties is prohibited, nor can such funds be frozen or seized (unlike deposits prior to maturity).

Based on the analysis of the current regulatory framework, restrictions no longer apply to a specific individual or legal entity in the following circumstances:

Accordingly, acquiring a Russian residence permit is the only practical way to exempt a foreign individual’s deposit from the application of the special regime.

Before applying for a residence permit, we recommend evaluating the following:

For further consultation or practical assistance, please contact our team, which delivers integrated tax, currency control and immigration advisory services to individuals.