As of 1 June 2026, bank deposits of “unfriendly” non-residents are subject to a special regulatory regime

On 1 June 2026, Presidential Decree No. 377 entered into force, introducing amendments to Presidential Decree No. 95. Under the revised framework, the special procedure established by Decree No. 95 now applies not only to certain categories of obligations but also to bank deposits held by persons from jurisdictions designated as “unfriendly” by the Russian Federation. 

Under a conservative interpretation of the new provisions, the repayment of deposit principal and accrued interest to unfriendly non-residents may be made only in compliance with the restrictions set out in Decree No. 95, namely through a Type “C” account or pursuant to a permit issued by the Government Commission. 

A limited exception may apply where the aggregate amount of payments made by a bank to all unfriendly persons does not exceed RUB 10 million per month. 

In practical terms, these amendments significantly restrict the ability of unfriendly non-residents to use bank deposits in Russia as an income-generating investment instrument. 

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