We previously informed that Presidential Decree No. 377 of 1 June 2026 extended the special procedure established by Decree No. 95 for discharging obligations to certain foreign creditors to bank deposits. The Bank of Russia has now clarified how the new rules should be applied.
The key clarification concerns the monthly threshold of RUB 10 million. For bank deposits, the threshold is calculated separately for each depositor based on the total amount of the bank’s obligations to that depositor in a calendar month, rather than on the bank’s obligations to all foreign creditors. If the amount owed to a particular depositor does not exceed RUB 10 million, the procedure under Decree No. 95 does not apply. If the threshold is exceeded, the obligation must be discharged by crediting the funds to a Type “C” account, unless a special permission has been granted. We note that the Bank of Russia had previously taken the position that the threshold should be calculated based on the total amount of all obligations of the debtor to all foreign creditors in a calendar month.
Decree No. 95 applies only to obligations under bank deposit agreements. Obligations under bank account and correspondent account agreements fall outside its scope.
The Bank of Russia also confirmed that the special procedure applies when the deposit is repaid and interest is paid. Before the obligation falls due, the bank is not required to change the status of the deposit, and deposits opened earlier are not automatically converted into Type “C” deposits. The deposit agreement may be extended; however, interest payments made upon extension remain subject to the requirements of Decree No. 95.
The clarification therefore substantially mitigates the effects of Decree No. 377, primarily by applying the RUB 10 million monthly threshold separately to each depositor. Funds will be credited to a Type “C” account only if the amount due to the relevant depositor within a calendar month exceeds the above threshold.