Who makes this, and how it is kept current
The Russia Counter-Sanctions Navigator is published by BCA Unternehmensberatung UG, a Stuttgart-based advisory firm working on Russian currency regulation and counter-sanctions since the first decrees of February 2022.
What it is
Since 28 February 2022 Russia has built a parallel body of law — Presidential decrees, Government Commission decisions, Bank of Russia “Information” notices — that decides whether money may cross the Russian border and on what terms. None of it is published in English. Most of it is not consolidated anywhere, including in Russian: a single question such as “may our Russian subsidiary pay a dividend to its German parent” turns on a decree, two clarifications and an extract from the minutes of a sub-commission.
This site reduces that body of law to a table: 74 operations, each with a status (permitted, prohibited, permit required), the date from which the status applies and the document it rests on. The Russian version has been maintained at usd.bcaun.com; this English version mirrors it card for card and adds the guides a non-Russian reader needs to make sense of the system.
How it is maintained
The Bank of Russia extends most temporary restrictions every six months (in March and September for cash, in June and December for transfers); the Government Commission changes its exit conditions roughly once a year; the President issues new decrees without a schedule. Every change is entered on the day it is published, and the verification date in the header is updated. If the date in the header is more than a month old, assume something may have moved.
Who
BCA Unternehmensberatung UG was founded in 2011 and has operated from Stuttgart since relocating its operations to the EU. The firm advises Russian-speaking and international clients on company formation, cross-border structuring and tax across more than forty jurisdictions; Russian counter-sanctions currency regulation has been one of its core areas since 2022. Written opinions ordered through this site are issued and signed by BCA Unternehmensberatung UG under German law.
What it is not
The navigator is reference material, not legal advice, and it does not cover Western sanctions on Russia — the EU, UK and US regimes are a different body of law with different authorities. Where a question involves both sides (it usually does), the written opinion deals with the Russian side; we will say so if the Western side needs separate counsel.
Contact
BCA Unternehmensberatung UG, Stuttgart, Germany · [email protected] · bcaun.com