Exceptions to the Application of the Temporary Procedure Established by Decree No. 95 to the Fulfillment of Obligations Related to Bank Deposits.
We previously reported that, effective June 1, 2026, the temporary procedure for fulfilling obligations to foreign creditors associated with unfriendly states, as provided for by Decree of the President of the Russian Federation No. 95 of March 5, 2022 (hereinafter— “Decree No. 95”) had been extended to cover the fulfillment of obligations related to bank deposits.
By Decree of the President of the Russian Federation No. 550 of August 4, 2026, the following relationships regarding the fulfillment of obligations on bank deposits were excluded from the scope of the temporary procedure for fulfilling obligations to foreign creditors associated with unfriendly states, as provided for by Decree No. 95:
- individuals who are foreign creditors
- branches, permanent representative offices, and other separate or independent structural units of organizations that are foreign creditors (hereinafter referred to as “Structural Units”), provided that such Structural Units are registered in the Russian Federation
The aforementioned persons are also entitled to receive, in rubles, funds that were credited by credit institutions in fulfillment of their obligations under deposits to “Type C” accounts during the period from June 1, 2026, to August 4, 2026.
