Bank deposits: changes to the temporary procedure for fulfilling obligations to foreign creditors

Presidential Decree No. 95 dated 5 March 2022 establishes a temporary procedure for fulfilling obligations to certain foreign creditors. Under this procedure, where the amount of monetary obligations exceeds RUB 10 million in a calendar month, settlement must be made by crediting the relevant funds to a bank account of type “C” in rubles. Effective 1 June 2026, the procedure was extended to cover liabilities relating to bank deposits. This change was enacted by Presidential Decree No. 377 dated 1 June 2026 (see our earlier publication Regulatory updates on foreign individuals’ deposits in Russia effective 1 June 2026: legal uncertainties and risks).

Presidential Decree No. 550 dated 4 August 2026 introduces an item 12¹ into Decree No. 95, excluding the following two categories of bank deposits from the scope of the special procedure: 

• Deposits held by foreign individuals;  
• Deposits held by branches, representative offices, separate subdivisions and other independent structural subdivisions of foreign creditors, provided that such ones are registered in the Russian Federation.

Foreign creditors, namely foreign individuals and Russia-registered subdivisions of foreign companies, have the right to receive funds in rubles that were credited by credit organizations to bank accounts of type “C” between 1 June 2026 and the effective date of Decree No. 550. In other words, the Decree allows these depositors to access funds previously credited to bank accounts of type “C” in connection with the fulfillment of obligations under the relevant deposit arrangements. 

NB: Decree No. 550 does not establish a special procedure for accessing such funds. To exercise this right, depositors should contact their service bank to clarify the applicable procedure.

The changes reverse the recent extension of the special procedure to bank deposits held by foreign individuals and Russia-registered subdivisions of foreign companies. As a result, such deposits are no longer subject to the special procedure for fulfilling obligations established by Decree No. 95.

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For further consultation or practical assistance, please contact our team, which provides integrated legal, tax, currency control and immigration advisory services to individuals, as well as full legal and tax support for the establishment, operation, and closure of subdivisions, branches and representative offices of foreign legal entities in the Russian Federation.