On June 1, 2026, the decision of the Bank of Russia Working Group dated June 1, 2026 No. PRG-43-11/1199 (hereinafter – “Decision”) and Presidential Decree No. 377 dated June 1, 2026 “On Amending Presidential Decree No. 95 of March 5, 2022 ‘On the Temporary Procedure for Fulfilling Obligations to Certain Foreign Creditors’” (hereinafter – “Decree No. 377”) were published, introducing changes to the current counter-sanctions regulation.
According to the text of the Decision, the Bank of Russia maintains a permissive regime for residents in connection with transactions involving the payment for shares, contributions, units in the property of foreign legal entities, as well as for the payment of contributions by residents to non-residents under joint activity agreements (hereinafter – the “Transactions”), without obtaining individual permits from the Bank of Russia, provided the following conditions are simultaneously met:
- The transaction is carried out in rubles or foreign currency for a total amount not exceeding the equivalent of 30 million rubles at the official exchange rate of the Central Bank of the Russian Federation on the payment date;
- As of the effective date of the Decision, the total volume of transactions by a resident made in favor of a single foreign legal entity shall not exceed the limit of 30 million rubles (taking into account transactions made by the resident in favor of such foreign legal entity since April 1, 2024).
The Decision enters into force on July 1, 2026, and repeals the previously effective decision of the Bank of Russia Working Group dated March 6, 2024, No. PRG-12-3/534, which had set a limit for carrying out the Transactions at a total amount not exceeding the equivalent of 15 million rubles at the official exchange rate of the Central Bank of the Russian Federation on the payment date per each foreign legal entity.
Basically, the Decision merely updates the financial limits on Transactions, which is a logical step two years after the date on which the relevant exemptions were introduced. In any case, the period from which the aggregate value of a resident’s transactions in favour of a foreign legal entity is reported is not interrupted by the new Decision. Any Transactions exceeding the threshold values will require approval from the Central Bank in accordance with Presidential Decree No. 126 of March 18, 2022.
The Decree No. 377 introduces amendments to the temporary procedure for fulfilling obligations to foreign creditors from unfriendly states by crediting funds to ruble type “C” accounts established by Presidential Decree No. 95 of March 5, 2022.
Previously, the scope of this procedure applied only to the obligations resulting from loans, borrowings and financial instruments. An amendment has now been made extending the temporary procedure for settlements via type “C” accounts to the obligations of Russian banks on deposits with foreign creditors from unfriendly states when the relevant limits are exceeded.
Thus, as of June 1, 2026, a Russian bank may pay income on deposits to persons from unfriendly states only within the limit of 10 million rubles per month, and the amount exceeding this limit must be credited to a type “C” account.