Amendments to Decree No. 95 of the President of the Russian Federation dated 5 March 2022 "On the Temporary Procedure for Performing Obligations to Certain Foreign Creditors"1  (hereinafter "Decree No. 95") have been adopted. They affect the temporary procedure for performing obligations to foreign creditors under bank deposit contracts.

We would like to remind you here that this measure, effective from 1 June 2026, stipulates that monetary funds should, after the termination of a bank deposit contract, be credited from deposits opened in the name of non-residents from unfriendly states at Russian credit institutions to a type C account (the so-called temporary procedure for performing obligations).

According to the new amendments, the temporary procedure for performing obligations does not apply to:

1)

bank deposits made by individuals who are foreign creditors;

2)

bank deposits made by the branches, permanent representative offices and other standalone or independent structural divisions of entities which are foreign creditors if the Russian Federation is the place of registration of these branches, permanent representative offices or divisions.

To all intents and purposes, the branches and permanent establishments of foreign companies, in case of the performance of obligations arising from bank deposits, are now equated to subsidiaries registered in Russia from unfriendly states which had previously been subject to the temporary procedure for performing obligations.

In addition, the categories of foreign creditors from unfriendly countries indicated above in points 1) and 2) are entitled to receive funds in roubles credited by credit institutions to type C accounts in the period from 1 June 2026 to 4 August 2026 (date of the entry into force of the new amendments), in other words, money held on type C accounts since 1 June 2026 will be returned to their owners for use at their discretion. In this case, the statement that the funds will be returned in roubles does not represent a change, as since 2022 bank deposits in Russian banks can only be received in roubles.

We will continue to keep you up to date on this topic.