In the past few days the following key restrictive measures were introduced to support the ruble exchange rate and the Russian economy:

  1. Russian foreign trade participants (e.g. exporters of goods and services) must sell 80% of their foreign currency revenues resulting from any kind of foreign trade contracts within 3 days from receiving them on their Russian bank accounts. This requirement applies to revenues received starting from 1 January 2022.
  2. Starting from March 2022 Russian residents, i.e. Russian entities, individuals and foreign citizens living in Russia under a residency permit, are not allowed to:

a. transfer foreign currency (without a special permit) to their accounts or deposits in foreign banks or other financial market participants;
b. provide loans (without a special permit) to non-residents in foreign currency and in rubles to residents of 43 countries that Russia regards as taking hostile action;
c. conclude (without a special permit) deals transferring ownership of securities and/or real estate with the residents of the mentioned 43 countries;
d. export foreign currency in cash in amounts exceeding the equivalent of USD 10,000.

Such transactions will be treated as unlawful and may trigger administrative fines from 75% to 100% of the transaction amount.

  1. The Central Bank of Russia issued an instruction to Russian brokers and depositaries that administer securities (shares and bonds) to suspend:

a. the processing of requests of foreign residents to sell Russian securities;
b. the processing of payments on securities (including dividends and interest on bonds) to foreign residents.

The restriction on dividends relates to joint stock companies. There are as yet no limitations on dividends on participation interests in limited liability companies that are not regarded as securities and are not administered by depositaries.

The above restrictions apply until further notice. The list of urgent measures supporting the ruble exchange rate is rapidly evolving. We will keep you informed of key updates.


Sergei Zhestkov is a partner in the Moscow office of Baker McKenzie and a licensed Russian advocate. He specializes in advising multinational corporate and private clients on the broad scope of tax and asset protection issues, and international tax and trust planning and structuring.