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The authorities may tighten control over payments by Russian companies to persons linked to "unfriendly" states, and banks have already begun refusing to carry out transactions that could breach the limit of 10 million rubles, the approach to which is changing in 2026, RBC reports, citing lawyers and consultants.

At the centre is the interpretation of a provision of Presidential Decree No 95, "On the Temporary Procedure for the Performance of Obligations to Certain Foreign Creditors", of March 2022. The requirement to perform such obligations (for example, dividend payments or loan repayments) by compulsorily crediting funds to special type C accounts, which effectively blocks them inside Russia, "applies to the performance of obligations in an amount exceeding 10 million rubles per calendar month" (or the equivalent in foreign currency; USD119,000 at the current exchange rate).

In June 2026, however, the Supreme Court issued a thematic review of how state commercial courts apply counter-sanctions legislation, which addressed the application of the 10 million ruble limit. After that the approach to determining the limit began to change, lawyers interviewed by RBC said. The wording used in the Supreme Court's review somewhat differs from the Presidential decree’s: "The temporary procedure for the performance of obligations established by Decree of the President of the Russian Federation No 95 applies to obligations in an amount above 10 million rubles per calendar month, or in an amount exceeding the equivalent of that sum in foreign currency."

Previously, in practice, it was considered possible to split an obligation exceeding 10 million rubles, or the equivalent, into several operational payments so that none exceeded 10 million a month. Now a different approach is taking hold, under which the limit must be applied to the obligation as a whole. So, if a company decides, for example, to pay dividends of 20 million rubles to "unfriendly" shareholders or participants, it will not be able to transfer the money freely even if it draws up a schedule of payments each meeting the condition of no more than 10 million a month.

The review does not create a new prohibition but records, at the level of the Supreme Court's presidium, an approach that lower courts had already applied, experts believe. In effect, it is an instruction to stop turning a blind eye to formal splitting and to assess instead the real business purpose of the transaction.

Such a categorical reading of the provision by the Supreme Court could prompt a retrospective reassessment of transactions carried out since 2022. Only the Bank of Russia is authorised to give official clarifications of this provision, and market participants hope one will follow.