In the midst of sanctions crack-down on the Russian economy the country’s authorities have drastically tightened control over and imposed limitations on investment operations. The principal countersanctions are the prohibition on transfers of foreign currency across national borders and limitations on deals with residents of unfriendly jurisdictions. The initial “counter-sanction” restrictions imposed by decrees of the RF President were: general prohibition on crediting of foreign bank accounts of Russian currency residents with foreign currency amounts and prohibition on transactions with securities and real property, to which residents of unfriendly countries are parties. Subsequently those prohibitions were modified and scaled backс by the Government Commission on Monitoring Foreign Investment in the Russian Federation (Gov. Commission) and the Central Bank.
Countering the transfers of foreign currency abroad is achieved both through stopping of transfers of foreign currencies (in access of the established limits) across the national borders of Russia and through prohibition on crediting (including from foreign sources) of foreign accounts of Russian residents with foreign currency amounts. Exceptions are allowed in cases of receipt of salary, rentals, dividends and interest income. However it is not allowed to receive many other kinds of income (for instance from sale of foreign real property to a non-resident) on foreign bank accounts. One should bear in mind that those restrictions also apply, in the opinion of Central Bank, to “special residents”, i.e. Russian citizens residing (including permanently) abroad.
The procedure for the obtainment of an approval of a transaction with Russian and foreign real property, to which residents of unfriendly countries are parties, has also been introduced. However, for some of such transactions (including gratuitous transfers between relatives and purchases of residential property from non-residents in case settlements are made through special accounts) no such approvals are needed. Before making each transaction one should check for most recent limitations because they change with the fluctuation of the economic situation.