How Russian counter-sanctions work: decrees, the Government Commission and the Bank of Russia
Russia's response to Western sanctions is not one law but a layered system of Presidential decrees, Government Commission decisions and Bank of Russia notices. Knowing which layer governs your question is half the answer.
Four layers of rules
Everything starts with Presidential decrees adopted under the 2006 law on special economic measures. The founding set is small and still in force: Decree No. 79 of 28 February 2022 (special economic measures), No. 81 of 1 March 2022 (loans and securities transactions with unfriendly persons), No. 95 of 5 March 2022 (type C accounts for debt to unfriendly creditors), No. 126 of 18 March 2022 (currency regulation, including payments for shares in foreign companies), No. 254 of 4 May 2022 (dividends and profit distribution), No. 430 of 5 July 2022 (repatriation), No. 529 of 8 August 2022 (foreign-currency deposits and bonds), No. 618 of 8 September 2022 (transactions with LLC participation interests) and No. 737 of 15 October 2022 (cash exports, capital reductions). Later decrees mostly amend these; the most recent are No. 377 of 1 June 2026 and No. 550 of 4 August 2026 on bank deposits of unfriendly creditors.
The second layer is the Government Commission for Control over Foreign Investment and its sub-commission, which issue individual permits where a decree requires one and publish general conditions as “extracts from the minutes”. The extract of 15 October 2024 (No. 268/1), for instance, is where the 60% discount and 35% budget contribution for exit transactions come from. These extracts are published by the Ministry of Finance, which acts as the sub-commission's secretariat.
The third layer is the Bank of Russia. It issues three different kinds of instrument that are easy to confuse: Board of Directors decisions, which set limits such as the USD 10,000 cash withdrawal cap; Working Group decisions (numbered PRG-…), which grant general permits for currency operations under Decree No. 126 — for example the RUB 30 million limit for paying for shares in foreign companies that took effect on 1 July 2026; and “Information”, a press release with regulatory effect that announces each six-monthly extension of the temporary restrictions. The “Clarifications” (numbered 1-OR, 4-OR and so on) explain how the decrees are to be read and are treated by banks as binding in practice.
The fourth layer is federal law, which has been used sparingly but decisively: Federal Law No. 470-FZ of 2023 created the “economically significant organisations” mechanism, and Federal Law No. 319-FZ of 4 August 2026 allows courts to terminate an unfriendly investor's right to buy back an asset it sold after February 2022.
Three statuses, not two
Every operation in the navigator carries one of three outcomes. Permitted means no special approval is needed, though ordinary currency-control documentation at the bank still applies. Prohibited means exactly that, with the usual carve-out of RUB 10 million per month for obligations to unfriendly persons, above which payment goes to a type C account. Permit required means the operation is lawful only with an individual permit of the sub-commission or, for currency operations under Decrees No. 79 and 81, of the Bank of Russia. A fourth, rarer status — “with Bank of Russia permit” — applies to cash exports above USD 10,000.
Who is “unfriendly”
The list of unfriendly states and territories is set by Government Directive No. 430-r of 5 March 2022 and covers the EU member states, the UK and its Crown dependencies and overseas territories, the US, Canada, Japan, South Korea, Singapore, Switzerland, Norway, Australia, New Zealand, Taiwan, Ukraine and a handful of smaller jurisdictions. A person is “connected with” an unfriendly state by citizenship, place of registration, principal place of business or principal place of profit. Two exceptions matter in practice: a company controlled by Russian persons, with the control disclosed to the Russian tax authorities, is not treated as unfriendly for the purposes of Decrees No. 81, 95, 254 and 618; and neither is a company controlled by persons from a friendly state where that control was established before 1 March 2022. The reverse also holds — a friendly-state company under unfriendly control is treated as unfriendly. The “Who is unfriendly” tab of the navigator sets out the tests with their sources.
The six-month rhythm
Most restrictions on individuals are temporary and are renewed by the Bank of Russia on a fixed cycle: cash foreign-currency withdrawals in March and September (currently until 9 March 2027), transfers abroad by non-residents from unfriendly states in June and December (currently until 7 December 2026). The permit requirement for paying for shares in foreign companies under Decree No. 126 is extended by Presidential decree each December (currently until 31 December 2026). Every one of these has been renewed each time since 2022, and the navigator's timeline flags the next expiry. It is safer to assume renewal and plan for it than to time an operation to an expected lapse.
Where to look
Primary sources are published in Russian only: decrees on the official legal-information portal (publication.pravo.gov.ru), Bank of Russia instruments on cbr.ru, sub-commission extracts on minfin.gov.ru. The navigator links each card to a search for the official text. Where a decree is classified “for official use” — as Decree No. 771 of 2023 on export proceeds is — its content is known only through Government resolutions and official statements, and the navigator says so.