Bank of Russia introduces amendments to C-type accounts regime

On 31 July 2025, the Board of Directors of the Central Bank of Russia made a decision to amend the decision of 21 November 2022 which established a special rouble C-type account regime (“Decision”).
The Decision amended the grounds for debiting funds from a C-type bank account opened for a non-resident.

In accordance with the Decision, a non-resident is now entitled to transfer funds to a Russian resident in connection with asset “exchange” transactions, as a result of which:

• the resident acquires ownership of securities; and
• assets blocked in international clearing systems is disposed of in favour of the non-resident.

The transfer of securities to a resident will require permission from the Governmental Commission.

Furthermore, in order to perform obligations to residents, a non-resident is now also allowed to transfer the funds in the amount of dividends that were previously credited to its C-type bank account. Nevertheless, such transfer of funds will also require permission from the Governmental Commission.

Such targeted amendments to the C-type account regime are not related to the asset exchange procedure introduced in 2023 by Decree of the President of the Russian Federation No. 844. It appears that the innovations are primarily aimed at increasing the attractiveness of private asset exchange transactions, given that the new ground for debiting funds from a C-type account is transactions under the “securities for securities” exchange mechanism, which previously took place only in private transactions.

We believe that private asset exchange will now be more attractive to Russian investors. Now, in addition to securities owned by non-residents (to which a significant discount was applied), Russian investors will also be able to count on funds blocked in C-type accounts.