Decree No. 95 · 5 March 2022

Type C accounts and the RUB 10 million monthly cap

The decree behind every type C account. Obligations of Russian debtors to creditors from unfriendly states above RUB 10 million a month are discharged in roubles into a blocked account in Russia.

What it does

Decree No. 95 introduced a “temporary procedure” for obligations of the Russian state, Russian companies and individuals to foreign creditors connected with unfriendly states. Payments up to RUB 10 million per calendar month per creditor may be made normally; above that, the debtor pays in roubles into a type C account opened in the creditor's name with a Russian bank, and the obligation is treated as performed. Using the balance — beyond Russian taxes, federal bonds and a few other purposes — requires a permit.

Paragraph 12 contains the most used exception: a foreign person controlled by Russian legal entities or individuals is not treated as unfriendly once the control has been disclosed to the Russian tax authorities. The scope of the decree was widened by Decree No. 254 (dividends), Decree No. 737 (liquidation and capital reduction) and Decree No. 377 (bank deposits, from 1 June 2026), and narrowed by Decree No. 550 (deposits of foreign individuals and branches, from 4 August 2026).

Status, October 2026

In force, without an end date. None of the 2022 decrees creating the type C regime is time-limited.

Operations that rest on it

5.5Granting a rouble loan to an unfriendly person controlled by a Russian person and disclosed as a CFC, or to a controlled friendly person (control established before 1 March 2022).Permitted6.8Repayment of a loan by a resident in roubles from a Russian account to an unfriendly person in an amount not exceeding RUB 10 million per calendar month.Permitted6.9Repayment of a loan by a resident in roubles to an unfriendly person above RUB 10 million per month — only by payment in roubles to a type C account.Permitted6.10Repayment of a loan by a resident to an unfriendly person controlled by a Russian person and disclosed as a CFC, or to a controlled friendly person.Permitted7.4Payments by residents upon reduction of charter capital (liquidation, bankruptcy) to persons of unfriendly states — via a type C account or up to RUB 10 million in aggregate per month.Permitted8.1Distribution of profit of LLCs, partnerships and cooperatives to participants that are foreign persons of unfriendly states, in an amount not exceeding RUB 10 million in aggregate per calendar month (or the equivalent in foreign currency).Permitted8.2Distribution of profit to the same participants above RUB 10 million per month (other than cases 8.3–8.6).Permit required8.3Distribution of profit above RUB 10 million per month — only by payment in roubles to a type C account.Permitted8.6Distribution of profit to participants that are unfriendly foreign persons controlled by a Russian person and disclosed as a CFC, or controlled by a friendly person.Permitted10.2Performance of obligations under credits/loans to unfriendly creditors above RUB 10 million per month, without crediting a type C account, by other means (set-off, compensation, novation).Permit required10.3The same up to RUB 10 million per month — termination by other means (set-off, compensation, novation).Permitted

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.

Dividends from a Russian subsidiary to a shareholder in an unfriendly state

The RUB 10 million monthly cap, type C accounts, the two routes to a permit, and the one structure that avoids the regime altogether.

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.

Intra-group loans with a Russian subsidiary: granting, repaying and the permit line

Which direction of lending is free, which needs a permit, how repayment to a Western lender works above RUB 10 million, and the new RUB 30 million limit for capital contributions.

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.

The Russian-control exception: disclosing control to the Federal Tax Service and what it unlocks

The one lawful way out of the “unfriendly” regime for a foreign company owned by Russians — the CFC notification, the tax office confirmation under Letter ShYu-4-13/13043@, and the decrees it switches off.

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.

Russian securities in unfriendly hands: Decree 138 segregation, type C income, the 2024 asset swap and what is left in 2026

For funds, custodians and family offices with Russian shares and bonds they cannot move: the segregation regime, where coupons and dividends go, the two rounds of the Decree 844 swap, substitute bonds and the new “In” accounts.

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