New restrictions on bank deposits of "unfriendly" creditors in Russia
5 June 2026
Legal alert
Moscow
Russia has introduced restrictions on the withdrawal of funds from bank deposits by "unfriendly" foreign creditors1.
What exactly has changed?
Foreign persons associated with "unfriendly" countries (foreign entities, their Russian branches and representative offices, and/or citizens of "unfriendly" countries) are prohibited from withdrawing funds from their deposit accounts with Russian banks in amounts exceeding 10 million rubles per month (or the equivalent in foreign currency) starting June 1, 20262.
As a general rule (unless the Russian authorities approve an alternative way), amounts in excess of this threshold must be credited by the bank to a special Type "S" account, which is subject to operational restrictions.
As a reminder, funds held in Type "S" accounts can be used for tax payments and a limited range of other transactions, but they cannot be used to settle commercial liabilities or be transferred abroad.
1 Decree of the President of the Russian Federation No. 377 of June 1, 2026, "On Amending the Decree of the President of the Russian Federation No. 95 of March 5, 2022, "On the Temporary Procedure for Fulfilling Obligations to Certain Foreign Creditors".
2 In the absence of official clarifications, there is a high probability that the regulations will be interpreted conservatively, posing a risk of a complete freeze on funds held in the deposit accounts of persons from "unfriendly" states.
