Decree No. 138 · 3 March 2023

Segregation of securities passed through unfriendly hands

Russian securities acquired through a chain involving unfriendly persons are segregated: no exchange trading, income to type C accounts.

What it does

Decree No. 138 stopped the trade of buying blocked Russian securities cheaply abroad and selling them in Russia at domestic prices. Russian securities acquired after 1 March 2022, and Eurobonds and substitute bonds acquired after 3 March 2023, where any holder in the chain was connected with an unfriendly state, are kept in segregated accounting by Russian depositaries and registrars, may not be sold on the organised market, and pay income into type C accounts.

The Bank of Russia's Board decision of 9 December 2025, applicable from 12 January 2026, simplified the mechanics: one certificate of status may cover a whole transfer, certificates may be exchanged by e-mail, and corporate actions no longer trigger a six-day verification wait. It has no retroactive effect.

Status, October 2026

In force. The Bank of Russia's Q&A on the decree was last updated on 24 July 2026.

Guides that discuss it

Need this applied to your facts?

A written opinion on your specific operation or structure — 2–3 pages, three business days, legal basis cited, from €490.

Order a written opinion →