Restrictions on bank deposits for foreign individuals and legal entities

Since 1 June 2026, Russian banks have significantly restricted the use of bank deposits for ‘unfriendly’ foreign individuals and legal entities. Funds currently held in bank deposits are effectively frozen for an indefinite period. There is a risk that the bank itself may independently open a ‘Type C’ rouble account in the name of a foreign depositor at another Russian bank and transfer the funds there.

Who is affected by the restrictions?

‘Unfriendly’ foreign legal entities and individuals without a Russian residence permit, as well as representative offices or branches of ‘unfriendly’ foreign entities that hold bank deposits in Russian banks.

Russian subsidiaries of ‘unfriendly’ foreign entities are not affected by these restrictions.

Which bank accounts are subject to the restrictions?

Only bank deposits, but not ordinary debit card accounts.

What limits does a Russian bank have on the use of frozen funds?

Limits have been set on the use of bank deposits in Russian banks for all ‘unfriendly’ foreign individuals and legal entities, amounting to no more than 10 million roubles per month. This restriction applies to the total volume of transactions of all ‘unfriendly’ entities within the bank, rather than to each client individually.

What can Russian banks do with frozen funds?

Russian banks have two options: to leave the money in a bank deposit and offer the client the option of setting up automatic renewal for an indefinite period, or, at its own discretion, to open a ‘C’ account on behalf of the foreign client at another Russian bank authorized to hold such ‘C’ accounts. As a rule, such authorization is held by large Russian banks that are typically subject to sanctions, such as Sberbank or Alfa-Bank. The transfer of funds to a ‘Type C’ account will be deemed to constitute the Russian bank’s proper fulfilment of its obligations under the bank deposit (savings) agreement.