Type C accounts: what goes in, what can come out, and the 2026 changes for deposits

Origin and scope

Decree No. 95 of 5 March 2022 introduced a “temporary procedure” for performing obligations to foreign creditors connected with unfriendly states. A Russian debtor — a company, a bank, an individual — discharges such obligations above RUB 10 million per calendar month (per creditor, in aggregate) by paying roubles into a type C account opened in the creditor's name with a Russian bank or, for securities, with a depositary. Up to the cap, payment may be made normally, including abroad (card 6.8); above it, only into the account (card 6.9), unless a permit allows otherwise (card 10.2).

The scope has grown by amendment. Decree No. 254 of May 2022 added dividends and profit distributions. Decree No. 737 of October 2022 added payments on capital reductions and liquidation. Decree No. 377 of 1 June 2026 added Russian banks' obligations under deposits — interest and principal — held by unfriendly creditors, closing a gap through which foreign depositors had been withdrawing. Decree No. 550 of 4 August 2026 then carved individuals and Russian-registered branches and representative offices of foreign companies back out: their deposits are paid normally, and amounts that banks had routed to type C accounts between 1 June and 4 August are released in roubles. For foreign legal entities holding deposits, the regime stays.

What the holder can do with a balance

A type C balance may be used, without a permit, for a short list of purposes set by the Bank of Russia's Board of Directors: paying Russian taxes, duties and fees; buying Russian federal government bonds; paying for Russian securities acquired through the same regime; and a handful of settlements within the type C perimeter. It may not be converted into foreign currency, transferred abroad, or paid to a Russian third party outside the list. Since January 2024 the balances are also protected from enforcement by creditors of the account holder, with an exception for judgments issued before 3 January 2024.

Getting money out otherwise requires an individual permit of the Government Commission or, for some categories, the Bank of Russia. Permits have been granted where the balance is matched by funds unfrozen for Russian investors abroad, and in the asset-swap schemes launched in 2023–2024. They are not granted on request.

Counting the RUB 10 million

The cap is counted per Russian debtor and per foreign creditor, across all obligations that fall under Decree No. 95 in the month: a loan instalment, interest, a dividend and a deposit payout to the same creditor are added together. Payments to different group companies of the same creditor are separate caps, which is why intra-group lending structures were reorganised in 2022. The Bank of Russia's Letter No. 12-4-2/3652 of 16 May 2022 sets out the counting rules; Clarification No. 1-OR of 22 March 2024 deals with discharging obligations by set-off, compensation or novation instead of payment, which above the cap again needs a permit (card 10.2) and below it does not (card 10.3).

Who is outside the regime

The regime applies only to creditors connected with unfriendly states, and the control exceptions apply here as they do elsewhere: a creditor controlled by Russian persons with disclosed control, or by friendly-state persons with control established before 1 March 2022, is paid normally (cards 6.10 and 8.6). A creditor from a friendly state under unfriendly control is inside the regime. Obligations in roubles and in foreign currency are treated alike — the account is always in roubles, and conversion happens at the Bank of Russia rate on the payment date.

Practical points

• The account is opened by the Russian debtor's bank on the creditor's behalf; the creditor's consent is not required, and in practice creditors learn of the account from the bank's notice.
• Payment into the account discharges the obligation under Russian law. Whether it does so under the governing law of a foreign-law loan is a separate question that Western courts have answered inconsistently.
• Interest on type C balances, where paid, accrues into the same account.
• A plan to “wait it out” should assume the regime lasts as long as the decrees do; none of the 2022 decrees has an expiry date.