Currency control is the full framework companies operate under — repatriation deadlines, contract registration, the documents the bank keeps asking for. Where it bites you, and how to build it into operations so payments stop stalling, is the question.
The repatriation deadline, contract registration, and the supporting documents each outbound payment needs — the points where payments stall.
Registered contracts, on-time repatriation, and a document pack ready before the bank asks — so payments execute rather than bounce.
Russia's currency control regime governs all cross-border financial flows involving Russian residents and non-residents. For foreign-owned Russian companies, currency control is a daily operational reality — every outbound payment, every intercompany transfer, every dividend distribution passes through an authorised bank that is legally required to verify compliance. Non-compliance carries significant penalties.
This guide covers the legal framework, repatriation obligations, documentation requirements for outbound payments, the key restrictions introduced since 2022, and practical compliance for the most common payment types.
Russia's currency control is governed primarily by Federal Law No. 173-FZ "On Currency Regulation and Currency Control" (2003), supplemented by:
Central Bank of Russia (CBR) Instructions — detailed rules for banks and clients
Presidential Decrees — expanded restrictions introduced since February 2022, primarily Decrees No. 79, 81, 126, 280 and subsequent amendments
Government Commission on Foreign Investment decisions — required for certain transactions involving non-residents from unfriendly jurisdictions
The law distinguishes between currency residents (Russian legal entities and individuals with Russian citizenship) and non-residents. A Russian LLC owned by a foreign parent is a currency resident — subject to full Russian currency control rules regardless of ownership structure.
One of the most important currency control requirements for Russian exporters and service providers is the obligation to repatriate foreign currency earnings — to bring foreign currency received from foreign counterparties back to Russia within the contractually specified timeframe.
When a Russian LLC exports goods or provides services to a foreign counterparty and receives payment in foreign currency (USD, EUR, CNY, AED, etc.), it must receive that currency into a Russian bank account within the timeframe specified in the underlying contract. The currency does not need to be converted to rubles — it can remain in the Russian bank's foreign currency account — but it must be received into a Russian authorised bank.
Pick your situation — we'll tell you where you stand:
The repatriation deadline is the date specified in the contract as the payment date. For advance payments received from foreign buyers, the repatriation obligation is discharged when the goods are shipped or service is delivered (i.e. the advance is "earned" by performance). Contracts without specified payment dates create currency control compliance risk — always include explicit payment terms.
From April 2022, Russia introduced a mandatory conversion requirement: exporters were required to convert 80% of foreign currency earnings to rubles within 3 days of receipt. This requirement has been progressively relaxed and as of mid-2026 the mandatory conversion rate is 0% — there is no requirement to convert foreign currency to rubles. However, the CBR and Government retain the authority to reimpose this requirement by decree, and it has been adjusted multiple times since 2022. Monitor for changes.
Russian residents (including Russian LLCs) face additional restrictions on transactions with non-residents from "unfriendly" jurisdictions — EU countries, USA, UK, Switzerland, Australia, Japan and others listed in Government Decree No. 430. Outbound payments to these counterparties (including to a foreign parent company) may require Government Commission approval or are subject to specific restrictions. Chinese, UAE, Turkish and Indian counterparties are not subject to these additional restrictions.
For foreign currency contracts above certain thresholds, the Russian LLC's bank assigns a Unique Contract Number (УНК) — replacing the former transaction passport system abolished in 2018.
Export contracts: above USD 6 million equivalent — UCN required
Import contracts: above USD 3 million equivalent — UCN required
Loan agreements: above USD 3 million equivalent — UCN required
For contracts below these thresholds, no UCN is required but supporting documents must still be provided to the bank for each payment.
For each outbound foreign currency payment, the Russian LLC's authorised bank will require:
Payment order — specifying amount, beneficiary, payment purpose (VO code)
Underlying contract — signed agreement between the Russian LLC and foreign counterparty
Invoice — for goods or services payments
VO code — currency operation type code from the CBR classifier (e.g. VO11100 for export advance, VO20100 for import payment, VO40015 for dividend)
Additional documents — depending on payment type: customs declaration for goods exports, acceptance certificate for services, WHT payment confirmation for dividend distributions
Banks have a legal obligation to refuse transactions that lack proper documentation. Build in 2–3 business days for bank review of outbound payments, particularly for first-time payment types or new counterparties.
Currency control requires supporting documentation for cross-border payments, and the bank checks it before executing. Building the pack before the bank asks is what stops the back-and-forth and lets payments clear.
Export proceeds have to be repatriated within the deadline, and a breach can mean a fine of up to 30% of the amount. Meeting the deadline, or structuring around it where possible, is what avoids the penalty.
Cross-border contracts above thresholds must be registered for payments to clear — an unregistered one stalls the transfer. Checking whether yours needs it, before the payment, is what keeps money moving.
This is the full currency-control framework for companies. Your question is where it bites you — the repatriation deadline, the contract registration, the document the bank keeps asking for — and how to build it into operations so payments stop stalling.
A payment held or a deadline near? Tell us the situation — we'll tell you what's missing.
Practical support for international business in Russia.