Guide to counter-sanctions: how to navigate the Central Bank’s restrictive measures
Amid increasing sanctions pressure and Russia’s response, businesses are increasingly facing numerous restrictions on financial transactions. To simplify navigation in this complex legal field, the Bank of Russia has published a “Navigator for Restrictive Measures” — a reference tool that systematizes the counter-sanctions measures in force as of August 1, 2025.
What is the “Navigator of Restrictive Measures”?
• It is an official reference document posted on the Bank of Russia website.
• It contains a collection of restrictions (prohibitions, special regimes, permissions) on financial and related transactions in force in the Russian Federation, as well as exceptions to them.
• The Navigator does not replace regulatory acts, decrees, and decisions—it only structures information and provides links to legislative sources and official explanations from the regulator.
• It is for reference purposes only: when applying restrictions to a specific transaction, it is necessary to additionally check the legislation in force at the time of its execution.
Structure and content
• The document contains approximately 493 items (transactions, deals) with details of participants, asset types, restrictions, and legal grounds.
• Transactions are grouped into major blocks:
1.Deposits and withdrawals through Russian banks, transfers and repatriation of currency.
2. Transactions with counterparties, divided into residents, friendly and unfriendly non-residents.
3. Financial assets: securities, bonds, insurance transactions.
4. Lending, loans, restructuring of obligations.
5. Fulfilment of obligations: payments, capital returns, distribution of profits, etc.
• In some cases, the Navigator notes exceptions, i.e. transactions to which restrictions do not apply or are applicable only subject to permission from the authorised bodies.
• The document contains references to regulatory acts: presidential decrees (Nos. 79, 81, 95, 126, 138, 198, etc.), federal laws, and official explanations from the Bank of Russia.
What’s new and what to look out for (2025)
1. Extension of restrictions on transfers abroad
In September 2025, the Bank of Russia extended restrictions on transfers abroad for another six months, from October 1, 2025, to March 31, 2026, inclusive.
· Resident individuals may transfer up to US$1 million (or the equivalent in another currency) per month to foreign accounts.
· There is also a limit on transfers via money transfer systems — up to US$10,000 (or the equivalent).
· The restrictions also apply to non-resident individuals from unfriendly countries who do not work in Russia.
2. Extension of economic measures until 2027
In October 2025, the government extended a number of counter-sanctions, particularly those related to foreign trade and restrictions on the import/export of goods and equipment, until December 31, 2027.
3. The new role of the Navigator
With the release of the 2025 version, the Navigator becomes the fifth edition of this type of document and is gradually becoming a standard reference for businesses and financial institutions.
It helps to systematize heterogeneous sources of restrictions that previously had to be searched for separately, reducing the risk of errors and increasing regulatory transparency.
How to use the Navigator: recommendations for businesses and consultants
1. Determine the type of transaction and the parties involved
Select the relevant category from the headings (table of contents) (transfers, loans, securities transactions, etc.), then proceed to the details.
2. Check the applicability of restrictions
Make sure that the terms of your transaction match the wording in the Navigator: counterparty type (resident/non-resident/friendly/unfriendly), asset, currency, execution dates, nature of the obligation.
3. Check exceptions and permissions
Some transactions may be permitted if they are authorized or if they fall under exceptions. The Navigator indicates such cases — it is important to rely on this information.
4. Use the reference database
The Navigator contains links to decrees, federal laws, and explanations from the Bank of Russia, which helps with more in-depth legal analysis.
5. Check for updates
Since regulations can change, it’s important to check the latest versions of the Navigator and the regulatory framework itself (decrees, laws, regulatory decisions).
The publication of the Restrictive Measures Navigator is a step by the Bank of Russia towards greater systematization and transparency of financial regulation in crisis conditions. It allows businesses and consultants to navigate the complex sanctions landscape more quickly and reduce legal risks when planning operations.
However, when working with specific transactions (especially cross-border transactions, transactions with counterparties from unfriendly countries, or transactions involving large assets), it is always necessary to:
• Classify the transaction correctly, taking into account all details,
• Check for exemptions and the need for authorizations,
• Check with the regulatory framework and updates,
• Seek legal expertise.
