Legal Update: Recent Clarifications on Foreign Deposit Restrictions, the Russian Supreme Court's Position on Counter-Sanctions, and Changes Affecting Highly Qualified Specialists (HQS)

1. Restrictions on deposits for foreign persons

Following on from the issue of restrictions on bank deposits for ‘unfriendly’ foreign individuals, on 14 July 2026 the Bank of Russia issued Official Clarification No. 1-OR, which improves the situation for foreign depositors.

The Bank of Russia has highlighted 4 key points:

• The restrictions do not apply to standard current or correspondent accounts, which had also been frozen by some banks;

• There is no prohibition on extending a bank deposit agreement, including by making the relevant amendments to the agreement;

• Banks are not obliged to open Type ‘C’ RUB accounts in the name of a foreign depositor at another authorised Russian bank and to transfer funds there. As a reminder, not all Russian banks have been authorised to open Type ‘C’ accounts;

• To comply with Decree No. 95, the amount of a bank’s liabilities to depositors must be calculated individually for each depositors within a single calendar month. Consequently, foreign depositors should be free to dispose of their deposits up to RUB 10 million per month.

2. Ruling of the Supreme Court of the Russian Federation on counter-sanctions No. 8/2026

The attachment contains an overview of frequently asked questions and answers regarding the artificial splitting of payments to foreign individuals from ‘unfriendly’ countries, as well as certain other issues.

3. Minimum wage increase for HQS

The attachment contains an overview of frequently asked questions and answers raised by our clients in connection with the increase in the minimum wage threshold for HQS.