“In” accounts for foreign investors in Russia

Since August 2025, foreign investors have been able to legally transfer funds abroad using special new “In” accounts. This became possible after the entry into force of a new mechanism introduced by Presidential Decree No. 436 of July 1, 2025, and the Decision of the Board of Directors of the Central Bank “On Establishing the Regime for In Accounts.” This mechanism is aimed at simplifying access to the Russian financial market while maintaining state control. The new procedure provides non-residents with certain guarantees and allows them to legally avoid restrictions imposed as part of the counter-sanctions policy.

What is an “In” account?

An “In” account is a special bank, deposit, brokerage, or trust account designed for foreign investors who wish to make new investments in Russia. The main feature of such accounts is separate accounting for assets and transactions, which allows investors to avoid restrictions previously imposed on foreign investments.

These accounts can be opened in rubles or foreign currency. They can be used to conduct transactions with Russian securities, place funds on deposit, and work with derivative financial instruments.

Opening procedure

To open an “In” account, an investor has to follow these steps:

•    contact a Russian credit institution or other authorized financial institution;

•    provide confirmation of investor status;

•    provide documents confirming the origin of funds;

•   enter into an agreement with a broker or manager. If all requirements are met, the financial institution is obliged to open an account. A special identifier must be specified when conducting transactions.

Terms of use and restrictions

Options for replenishing an “In” account:

•    from abroad;

•    from other accounts of the same type (“In”);

•    in the form of income from already invested funds.

Currency conversion and transfers between similar accounts are also permitted. However, replenishment from standard Russian accounts and cash withdrawals are prohibited.

Debits are only possible within the framework of investment transactions, the return of erroneously credited funds, or transfers between “In” accounts. A separate regime is established for accounting for securities in custody accounts: they can be credited during clearing settlements, corporate actions, or the return of collateral, and debited during the transfer of rights, redemption, or court decisions.

Risks and prospects

Despite the official easing of restrictions and the availability of guarantees, analysts note that a large influx of foreign investment is not expected.

The main reasons are:

•    High risk of secondary sanctions;

•    Fears related to the potential blocking/seizure of assets in Russia as part of retaliatory sanctions;

•    Technical difficulties with transferring funds (especially in dollars and euros) due to the disconnection of a number of banks from international payment systems.

The most likely participants in the new mechanisms are likely to be investors from the CIS, the Middle East, and Asia, although their interest in Russian assets remains limited for now.