Bank Deposits Brought Within Russia’s Special Countersanctions Regime for Obligations to “Unfriendly” Creditors

On June 01, 2026, the President of the Russian Federation signed Decree No. 377, "On Amending the Presidential Decree of the Russian Federation of March 05, 2022, No. 95 'On the Temporary Procedure for Fulfilling Obligations to Certain Foreign Creditors'" (“Decree No. 377”).

The amended decree introduces changes that establish a temporary procedure for fulfilling obligations owed to certain foreign creditors related to “unfriendly” states, expanding the scope of the existing countersanctions regime by explicitly including obligations arising from bank deposits and deposit accounts within the regulated sphere.

For more information about the recent changes, practical implications and market impact click here.