Russia has lifted the temporary restrictions that placed many foreign individuals’ ruble‑denominated bank deposits under a special settlement regime, allowing eligible customers to recover funds that had been moved to restricted Type C accounts.
Background
- Presidential Decree No 95 (5 Mar 2022) created a temporary procedure for Russian debtors to settle obligations to foreign creditors from “unfriendly” states. Obligations exceeding 10 million rubles (≈ US $119 k) per month had to be paid in rubles through a Type C account unless a competent authority approved another method.
- Presidential Decree No 377 (1 Jun 2026) amended the regime to include bank deposits. The amendment was brief and did not clarify how the 10 million‑ruble threshold should apply to depositors, nor did it distinguish between corporate and private accounts.
How banks interpreted the amendment
- Several major banks (Sberbank, T‑Bank, Alfa‑Bank, VTB) imposed restrictions on foreign‑national deposits, sometimes blocking withdrawals, transfers, or closures.
- In some cases, deposits of less than 1 million rubles (≈ US $11.9 k) were affected because banks treated the 10 million‑ruble limit as an aggregate across all foreign customers rather than per depositor.
- Affected groups included holders of highly qualified specialist permits, participants in the Shared Values Visa program, and ethnic Russians returning from “unfriendly” states.
Central‑bank clarification (14 Jul 2026)
The Bank of Russia issued Official Clarification No 1‑OR, addressing four key points:
- Scope of Decree 95 – applies only to obligations under bank‑deposit agreements, not to ordinary current‑account or savings‑account agreements.
- Timing – the special procedure does not apply before a deposit’s principal or interest becomes due; banks cannot pre‑emptively reclassify an unmatured deposit as a Type C account.
- Amendments – extending or amending a deposit agreement is permitted, though any interest that becomes due must still follow the applicable rules.
- Per‑depositor calculation – banks must assess the 10 million‑ruble threshold separately for each foreign depositor each calendar month, rejecting the aggregate‑bank interpretation.
The clarification reduced the risk that small personal deposits would fall under the regime solely because of a bank’s overall foreign‑client exposure.
Presidential exemption and recovery route (4 Aug 2026)
Presidential Decree No 550 expressly excluded bank deposits held by individual foreign creditors from the temporary settlement procedure. The decree also covered qualifying branches and permanent representative offices of foreign organisations that are registered in Russia.
- Eligible individuals and Russian‑registered foreign business units may receive, in rubles, the amounts that banks transferred to Type C accounts between 1 Jun and 4 Aug 2026.
- This provision creates a legal mechanism for reversing the earlier restrictions, not merely preventing future ones.
Relation to broader investment incentives
- Presidential Decree No 436 (1 Jul 2025) introduced “In” accounts for new foreign investment, allowing deposits, securities, IPOs, and derivatives, with withdrawal guarantees.
- The Bank of Russia later issued operating rules for In accounts, and lifted domestic foreign‑currency purchase limits for investors from “unfriendly” states entering under this framework.
- Existing Type C balances cannot be automatically transferred to In accounts; they must be moved through separate legal routes.
Additional pathways for legacy Type C balances
- Under Federal Law No 173‑FZ, a foreign citizen with a Russian residence permit is classified as a “currency resident” and is not a foreign creditor under Decree 95. Documentation of residence permits allows such holders to close Type C accounts and move funds to ordinary accounts.
- The Russian Golden Visa (investor‑residence program) provides a route to permanent residence without first obtaining a temporary permit; Golden‑Visa holders can also unlock Type C funds once their residence status is confirmed.
Significance
The correction—from the central‑bank clarification to the presidential exemption—was completed in 64 days, demonstrating a rapid policy response despite the broader geopolitical context. While only a limited number of foreign private depositors were directly affected, the episode underscores the Russian government’s priority to maintain access for foreign residents and investors and to differentiate legacy, sanction‑linked assets from new capital inflows.
Source article: www.imidaily.com
