Liquidation payouts, capital reduction and cash export
Brought payments on liquidation, capital reduction and bankruptcy to unfriendly participants under the type C regime, and put cash export above USD 10,000 under Bank of Russia permit.
What it does
Paragraph 3 of Decree No. 737 applies paragraphs 2–9 of Decree No. 95 to payments made to persons of unfriendly states on liquidation, reduction of charter capital and bankruptcy: up to RUB 10 million a month normally, above that into a type C account or under a permit. It also governs the export of cash foreign currency and monetary instruments above the equivalent of USD 10,000, which requires a Bank of Russia permit, and sets the procedure for transactions with interests in Russian banks and other financial institutions.
Status, October 2026
In force, without an end date. See the liquidation guide.
Operations that rest on it
Guides that discuss it
How Russian counter-sanctions work: decrees, the Government Commission and the Bank of Russia
Who issues what, which instruments actually bind a bank, and why the answer to a simple question is usually spread across four documents.
The cost of exiting Russia in 2026: the 60% discount, the 35% contribution and the end of the buy-back
What a Western seller actually receives after the sub-commission's conditions, how long a permit takes, and what Law 319-FZ did to buy-back options.
Type C accounts: what goes in, what can come out, and the 2026 changes for deposits
The mechanism behind every “RUB 10 million per month” rule — who must use it, what a balance can be spent on, and what Decrees No. 377 and 550 did this year.
Decree No. 618: getting a Government Commission permit for a transaction with a Russian LLC interest
What needs a permit, what does not (including the 2025 and 2026 Ministry of Finance clarifications), what goes in the file, how long it takes and what happens at the notary.
Liquidating a Russian subsidiary with an unfriendly shareholder: permits, payouts and timing
Winding up instead of selling — whether the liquidation decision needs a permit, how the liquidation proceeds reach the parent (they mostly do not), the tax on the way out and a realistic timetable.