Immediate consideration: asset repatriation and Russian currency control regulations enforcement risk

Alert: Immediate consideration — asset repatriation and Russian currency control regulations enforcement risk Effective: April 2026

Russian currency control legislation imposes mandatory repatriation obligations on Russian resident entities — including subsidiaries and joint ventures with foreign shareholders — requiring that foreign currency earnings from export transactions be returned through authorised Russian banks within prescribed timeframes. As the regulatory framework has continued to evolve since 2022, several temporary relaxations introduced by presidential decree and Central Bank instruction have lapsed or been revised. Foreign creditors and asset holders operating through Russian structures should treat the current position as requiring immediate review.

Foreign creditors with claims against Russian counterparties, and foreign shareholders holding interests in Russian entities, face a dual exposure under this framework. First, a Russian debtor's undisclosed failure to repatriate earnings can reduce the recoverable asset base – a pattern that arises in distressed asset situations and is not always visible from statutory accounts alone. Second, a foreign-owned Russian entity that has permitted intra-group transfers or distributions without proper currency control compliance may itself face enforcement proceedings by the Federal Tax Service or Federal Customs Service, each of which acts as a currency control agent under Russian law. Penalty exposure under the standard interpretation can reach the full value of the amount not repatriated, making this one of the higher-consequence compliance risks in the Russian enforcement landscape.

Recommended action:

1. Review whether your Russian subsidiary, joint venture, or SPV has met all repatriation deadlines applicable to export contracts and intra-group arrangements concluded since 2022.
2. Verify that any pending or recent distributions from Russian entities were routed through an authorised bank and supported by the required currency control documentation.
3. If you are pursuing enforcement or asset tracing against a Russian counterparty, instruct counsel to assess whether undetected repatriation violations have affected the available asset pool before proceedings are commenced.

For guidance on asset repatriation compliance and foreign creditor enforcement strategy in Russia, see also our Asset Tracing & Recovery practice page and related analysis: Navigating asset repatriation and Russian currency control regulations.

Speak to our team — info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors and institutional investors on enforcement strategy, repatriation compliance review, and distressed asset recovery under Russian law. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

— Elizaveta Razina Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/