Dear Colleagues,

in response to frequently asked questions, we have prepared a comprehensive overview of the administrative and regulatory requirements accompanying the procedure for opening and maintaining bank accounts for legal entities with foreign participation in the Russian Federation.

The issue of banking services and access to bank accounts is, undoubtedly, one of the most sensitive for any organisation, especially if the founder is located outside the Russian Federation but wishes to retain control over the process.

It is important to bear in mind that ignoring the local specifics of currency control, beneficial ownership identification requirements and document execution rules entails a direct risk of transaction blocking, significant fines and, as a consequence, breach of obligations to counterparties and fiscal authorities.

We hope that our overview will help you understand the key nuances.

1. Current Landscape of the Banking System of the Russian Federation

1) Which banks operate in the Russian Federation?

The Russian banking sector is a highly concentrated system comprising a large number of banks under the strict supervision of the Central Bank.

As of 2025–2026, the total number of operating credit institutions is slightly over 300 (in previous years, the number of banks exceeded 1,000, but the Central Bank has been systematically “cleaning” the market over several years by revoking licences from unscrupulous or loss-making banks).

Among the overall mass of banks, several particularly large institutions stand out, which are officially included in the list of so-called “systemically important credit institutions”.

This list comprises banks whose scale, interconnections with other market participants and share in the economy are so great that their failure would pose a threat to the entire Russian financial system. Their market share remains overwhelmingly dominant — they account for about 80% of the total assets of the Russian banking sector.

The list of systemically important credit institutions, approved by the Bank of Russia, as of 2026 includes 12 banks:

• Sberbank,
• VTB,
• Gazprombank,
• Alfa-Bank,
• Promsvyazbank (PSB),
• Rosselkhozbank,
• T-Bank,
• Moscow Credit Bank (MCB),
• Bank DOM.RF,
• Sovcombank,
• Raiffeisenbank,
• UniCredit Bank.

The Russian banking system includes both purely Russian structures (100% Russian capital) and banks that are part of international banking groups (e.g., Raiffeisenbank, UniCredit Bank, OTP Bank, etc.).

Some Russian banks have their own presence structures in other countries. For example, VTB is represented in China (VTB Shanghai), India (VTB New Delhi) and a number of CIS countries; Sberbank is represented in India (Mumbai and New Delhi).

2) Sanctions and international settlements

A number of banks, including systemically important ones, are subject to blocking sanctions by the US, the EU and the UK, which makes cross-border payments in US dollars and euros through them critically difficult and often impossible.

For international settlements in the aforementioned currencies, banks not subject to direct blocking sanctions retain some limited functionality. At the same time, many banks offer the option of conducting settlements in other national currencies.

If intend to use a particular bank for international settlements, one should first check the availability of correspondent accounts for settlements in the required currency from the relevant jurisdiction and additionally verify with the chosen bank the feasibility of executing the payment.

3) International settlements. Currency control.

Special attention should be paid to the currency control system. Russian legislation (Federal Law No. 173-FZ of 10 December 2003 “On Currency Regulation and Currency Control”) imposes on banks the functions of currency control agents.

This means that the bank is not merely a service organisation, but acts as a supervisory authority that has the right to request supporting documents for each foreign trade contract or transaction with a non-resident (regardless of the currency) and is obliged to suspend transactions if discrepancies or signs of misuse of funds are detected.

The depth and detail of control depend on the amount:

• For payments up to RUB 600,000 (or equivalent in foreign currency), it is sufficient to indicate the currency transaction type code in the payment order;
• from RUB 600,000 up to the threshold values (RUB 3 million for imports/loans, RUB 10 million for exports), the bank will request supporting documents (the contract itself, invoice, acts, waybills) to process the transaction;
• For amounts from RUB 3 million for import contracts and loan agreements / RUB 10 million for export contracts, the so-called “contract registration” becomes mandatory – a special procedure for registering the agreement with the bank’s currency control department.

If the final amount is not fixed in advance in the contract, the principle of cumulative total applies: as soon as the total volume of payments or shipments under the contract reaches the threshold, the contract must be registered.

Upon registration, the bank assigns a unique contract number (UCN) to the agreement. Thereafter, this number must be indicated in all payment documents and customs declarations under this contract.

If the contract is registered late, this may be treated as a violation of currency legislation and result in a fine.

The currency control system applies to both outgoing and incoming payments with foreign counterparties.

For incoming payments in foreign currency, the funds are initially credited to a so-called “transit account”, which is opened simultaneously with the current settlement account in the relevant currency by default. The funds remain blocked on the transit account until the company provides the bank’s currency control department with supporting documents that serve as the basis for subsequent crediting of funds to the current settlement account.

Thus, the basic account structure for a company engaged in international settlements, for example in CNY (or any other foreign currency), will look as follows:

1. Settlement account in rubles
2. Transit account in CNY
3. Settlement account in CNY.

4) Domestic settlements

Domestic settlements are conducted strictly in rubles.

Domestic transfers between legal entities (B2B) within the Russian Federation are carried out promptly via the Faster Payments System (FPS) or direct correspondent accounts.

When making settlements with individuals (B2C), legislation requires the legal entity to use so-called online cash registers (fiscal registrars) with real-time transmission of data on each payment to the tax service. The absence of a connected online cash register is grounds for refusal to open acquiring services and entails administrative liability.

5) Technical features of payment execution

The vast majority of payments are made online via the company’s personal account (the bank-client system of the servicing bank).

Signing is carried out either through an electronic digital signature (EDS) or through one-time codes that may be sent via SMS, email, or in another manner depending on the bank.

Russian banks operate a strict hierarchy of access to the account, which is set out in the terms and conditions of account servicing with a clear distinction between the legal status of signatories.

In the basic scenario, by default, a payment is signed by the signature of an authorised person. As a rule, this is the General Director of the company.

Otherwise, the structure of access with/without signing rights can be built according to the company’s individual preferences.

First signature grants the right to dispose of funds. Usually this is the General Director. A critically important nuance is the possibility of appointing several persons with first signature rights (e.g., Director, Finance Director, representative of the head office). For making a payment, one first signature is sufficient, unless otherwise specified in the account servicing terms.

Second signature has a control function (e.g., for the Chief Accountant). If the terms require “Two signatures”, the payment can only be made with the signatures of both authorised persons. The presence of a second signature is not mandatory, but is generally available in most banks upon the company’s request.

Operator access is granted to technical staff (managers, accountants) without signing rights. This status allows them to prepare payment orders and view statements, but does not allow them to send funds to the bank. The final confirmation of the transaction in such case is made by the signatory.

Most banks allow you to set up an individual signing hierarchy – for example, a payment may require only one signature or may not be sent without being signed by at least two signatories.

2. Scenarios for opening an account depending on the legal form

Analysis of current practice allows us to distinguish three independent scenarios, each with its own regulatory and procedural features.

a) Opening an account in the Russian Federation for a foreign legal entity

As a rule, this option is considered by foreign companies that do not conduct permanent business activities in the Russian Federation, do not have employees and an office in Russia, but need a bank account for one-off or periodic settlements with Russian counterparties.

It is important to know that before starting the account opening procedure, the foreign organisation must be registered for tax purposes in the Russian Federation and obtain a TIN (Taxpayer Identification Number). This does not mean registration of a representative office or branch, but only obtaining a TIN for the purpose of financial transactions.

According to Federal Law No. 416-FZ of 17 November 2025, from 1 September 2026, the registration of a foreign organisation with the tax authority in connection with opening an account in a Russian bank will be carried out on the basis of an application from the bank. The foreign company will no longer have to interact directly with the tax authority at this stage – this function is officially transferred to the credit institution.

The tax authority is obliged to register the foreign organisation within 5 working days from the date of receipt of the application from the Russian bank. Within the same period, the Federal Tax Service sends to the bank, in electronic form, an extract containing information about the registration of the foreign organisation, indicating its TIN and RPC (Reason for Registration Code).

Thus, from the moment of submitting documents to the bank until the account is opened and transactions can begin, a little over a week may pass, provided the full package of documents is available.

Registration as a taxpayer in itself does not give the foreign company the right to engage in entrepreneurial activity in the Russian Federation. The account may be used exclusively for settlements not related to the conduct of commercial activities through a permanent establishment.

In addition to the need to obtain a TIN, an indicative package of documents required for opening an account may include:

• Extract from the trade register (or equivalent) of the country of registration or another document confirming the legal status of the foreign company;
• Document confirming the company’s registration as a taxpayer in the country of residence, indicating the taxpayer code (or its equivalent);
• Constituent documents of the foreign legal entity (charter, certificate of registration, decision on establishment);
• Documents confirming the authority of the manager and persons entitled to sign;
• Passport of the General Director and other authorised persons (notarised copy with translation);
• Power of attorney for representatives in Russia (if necessary);
• Statement of beneficial ownership indicating the full chain of ownership down to the ultimate natural persons.

It is important to note that the actual list of required documents may vary significantly depending on the bank, so before opening an account you should always clarify the requirements of the specific bank.

b) Opening an account in the Russian Federation for a Russian company – a subsidiary of a foreign founder

This scenario is the most common for foreign investors planning to conduct full-scale business activities in the Russian Federation.

In this case, the foreign legal entity acts as the founder (participant) of a Russian Limited Liability Company (LLC), which is registered in accordance with Russian legislation and is an independent legal entity – a resident of the Russian Federation.

Thus, the account is opened in the name of the Russian legal entity (resident), and not in the name of the foreign company. This means that the document requirements and procedures are determined by the status of a resident; however, the bank is in any case obliged to conduct an in-depth verification of foreign beneficial owners and the ownership structure.

An indicative list of documents for opening an account may include:

Documents of the Russian LLC (resident):

• Charter of the Company in the current version;
• Decision of the sole founder on the establishment of the LLC or Minutes of the general meeting of founders;
• Certificate of registration with the tax authority (TIN, OGRN – Primary State Registration Number);
• Record sheet from the Unified State Register of Legal Entities (USRLE);
• Order (decision) on the appointment of the General Director;
• Documents confirming the legal address of the company in the Russian Federation (lease agreement, guarantee letter).

Documents of the foreign founder company:

• Registration documents of the foreign company confirming its legal status under the laws of the country of registration;
• Extract from the trade register (commercial register) of the country of registration;
• Charter of the foreign company (certificate of incorporation);
• Decision of the authorised body of the foreign company on the establishment of the LLC in the Russian Federation;
• Documents confirming the authority of persons who signed the constituent documents;
• Documents on beneficial owners and ownership structure.

All documents of the foreign founder company must be legalised (apostille or consular legalisation) and have a notarised translation into Russian.

Identity documents of signatories:

• Passport of the General Director of the LLC (notarised copy with translation, if the Director is a foreign citizen);
• Passports and contact details of all persons who will have access or signing rights.

It is important to note that the actual list of required documents may vary significantly depending on the bank, so before opening an account you should always clarify the requirements of the specific bank.

The timeframe for opening an account, with a full package of documents, is on average from 3 to 14 business days.

c) Opening an account in the Russian Federation for a representative office/branch of a foreign company

This scenario is implemented when a foreign company intends to conduct permanent activities in Russia, have staff, conclude contracts and carry out other commercial activities through its separate subdivision.

A branch or representative office is not an independent legal entity, but acts as a separate subdivision of the foreign company.

It is important to note that opening a branch or representative office requires mandatory accreditation with the authorised state bodies of the Russian Federation – a legal procedure for registering a subdivision of a foreign organisation in the Russian Federation.

List of documents for opening an account for a branch/representative office:

• Certificate of accreditation of the branch/representative office in the Russian Federation;
• Regulations on the branch/representative office (certified copy);
• Constituent documents of the foreign legal entity (charter, certificate of incorporation);
• Document on the appointment of the head of the branch/representative office;
• Identity documents of the head of the branch and signatories;
• Documents on beneficial owners of the foreign company.

The foreign parent company is entitled to transfer funds to its branch or representative office in Russia without opening special accounts and without restrictions. However, the branch or representative office itself is obliged to open a bank account with an authorised Russian bank to carry out its activities.

If the parent company is a resident of an “unfriendly state” from the relevant list, the reverse transfer of funds from the Russian Federation will be restricted.

3. Other features

3.1. Access of the foreign head office to the account: Foreign representative as signatory

In many cases, the foreign head office wishes to have access to bank accounts for additional payment verification or simply for control purposes.

A representative of the head office may generally be granted signing rights (first or second, depending on the company’s wishes), but it is important to take into account a number of technical requirements that may affect the feasibility of arranging such access.

To implement access and signing rights for a non-resident, the following mandatory conditions must be met:

1. Possession of a Russian mobile phone number. This requirement is established by Federal Law No. 115-FZ for identification of users of the remote banking system (RBS). The SIM card must be issued in the name of the individual, or documentary confirmation of ownership of the number must be provided. Under current rules, the acquisition of a Russian SIM card is carried out only in person and is linked to the individual’s passport data. Personal presence of the non-resident in the Russian Federation will be required.
2. Possession of an e-mail address. The bank sends all legally significant notifications, requests and information about suspicious transactions strictly to the specified e-mail address.

3.2. Annual disclosure of the beneficial ownership structure

The obligation to disclose the beneficial ownership structure is not a one-time action when opening an account.

In accordance with the requirements of Federal Law No. 115-FZ “On Counteracting the Legalisation (Laundering) of Criminally Obtained Incomes and the Financing of Terrorism”, the client is obliged at least once a calendar year to provide the bank with an updated Statement of Beneficial Ownership.

The statement must indicate the full chain of corporate ownership down to the ultimate natural person, including passport data, citizenship and share of participation (direct and indirect). In the event of changes in the composition of participants or the structure of the authorised capital, the information must be sent to the bank within 7 working days from the date of such changes.

Under the provisions of Law No. 115-FZ, failure to provide updated beneficial ownership data is an unconditional ground for blocking debit transactions on the account. The bank will not be able to make payments to the budget (taxes, fees) or to counterparties until it receives the current information.

FAQ: Answers to frequently asked questions

Question 1. Can a foreign company open an account in a Russian bank?

Yes, a foreign company has the right to open a settlement account in a Russian bank both in rubles and in foreign currency. Russian legislation expressly provides for this possibility: a credit institution is entitled to open a bank account for a foreign legal entity.

The procedure includes mandatory registration of the foreign organisation for tax purposes in the Russian Federation and obtaining a TIN.

Under the rules effective from 1 September 2026, the foreign company no longer submits an application for a TIN to the tax service on its own. Now the bank takes over all communication with the Federal Tax Service – after passing identification and document verification, the credit institution independently sends to the tax authority an application for registration of the company. The tax inspectorate must register the foreign organisation within 5 working days and assign it a TIN.

At the same time, it is important to note that registration as a taxpayer in itself does not give the foreign company the right to conduct permanent business activities in the Russian Federation through a permanent representative office. The account may be used for settlements not related to commercial activities through a permanent establishment.

Question 2. Can a representative of a foreign founder have signing rights?

Yes, a representative of a foreign founder (including a foreign citizen who is not a resident of the Russian Federation) may be granted signing rights on the bank account of a Russian company.

To do so, the following conditions must be met:

1. Documentarily confirmed authority. The authority must be duly formalised – as a rule, in the form of a power of attorney issued by the foreign founder (or the Russian company) to a specific representative. The power of attorney must be notarised or legalised in the prescribed manner (apostille or consular legalisation) and submitted to the bank with a notarised translation into Russian.
2. Identification of the individual. The bank is obliged to identify the representative in accordance with the requirements of Federal Law No. 115-FZ. For a foreign citizen, a passport with a notarised translation will be required.
3. Possession of a Russian mobile phone number and an e-mail address for access to the remote banking system (RBS).

Please note: banks may impose additional requirements on the execution of powers of attorney from foreign legal entities, so we recommend that you agree the form of the document with the chosen bank in advance.

Question 3. Is personal presence required to open an account in the Russian Federation?

A credit institution is prohibited from opening a bank account for a legal entity without the personal presence of its representative. A similar requirement applies to foreign clients – an account cannot be opened without the personal presence of a foreign citizen or a representative of a foreign legal entity.

Exceptions to the general rule:

1. The representative has already been identified by the bank. If a representative of the legal entity who has the right to act on behalf of the company without a power of attorney has already been identified by the given credit institution in person and is being served by that bank, then repeated personal presence for opening a new account is not required.
2. Identification was carried out remotely. The legislation allows for the possibility of opening an account for a foreign client without personal presence if the identification was carried out in accordance with the established remote identification procedure. However, in practice this possibility is limited.

Practical situation: despite the existence of legislative exceptions, the vast majority of Russian banks in any case require a personal visit by the head or authorised representative to the bank branch for corporate clients.

Question 4. Can a company have accounts in more than one bank?

Yes, it can. The number of banks in which an organisation may open accounts is not limited.

However, it is important to bear in mind that a large number of banks can significantly complicate administration, since each bank may have its own specific document requirements and deadlines for their submission.

We will be happy to answer any additional questions and to assist in preparing documents for opening an account, taking into account the individual features of your business.