Currency control for Russian exporters in 2026

What currency control is and who runs it

Currency control in Russia is a system of audits and approvals through which the state tracks the movement of money between residents and non-residents and ensures that export revenue returns to the country. It is formalised in Federal Law No. 173-FZ "On Currency Regulation and Currency Control" and the Bank of Russia's secondary acts. For the exporter this is not an abstraction — it is a set of mandatory procedures without which the bank simply will not process a payment from a foreign buyer.

The conceptual scheme is three-tiered. At the top sit the Bank of Russia as the currency-regulation authority and the Federal Tax Service as the authorised currency-control body. Below them are currency-control agent banks: every credit institution servicing operations with non-residents performs the agent function and is required to verify each cross-border operation. On the third tier are the clients: resident exporters on one side and foreign counterparties on the other.

There are three goals of control: protecting the balance of payments (revenue must return to Russia), counter-acting the shadow outflow of capital and the laundering of criminal proceeds (here currency control links up with 115-FZ), and tracking the tax base of foreign-trade contracts.

Who is a currency-control agent bank

It is a commercial bank holding a Bank of Russia licence for banking operations and required by 173-FZ to perform agent functions. No special "currency-agent licence" is needed — the duty is built into the banking licence itself. Any bank where you hold a settlement account is your currency-control agent for the operations going through that account.

In practice this means: for every cross-border operation responsibility lies simultaneously with the exporter and the bank. The bank verifies the documents and the qualification of the operation; you are responsible for the accuracy of the information and the deadlines. If a bank carries out a questionable operation without proper verification — responsibility lies with the bank, up to revocation of its licence. If the exporter submitted false documents — responsibility is administrative (Article 15.25 of the Code of Administrative Offences) or criminal (Article 193 of the Criminal Code in case of large amounts). The powers of currency-control bodies are split between the Bank of Russia and the FNS: FNS — currency-control function.

More on the role of the Bank of Russia as the financial-market regulator is on the regulator's site: Bank of Russia — currency-control function.

173-FZ for the exporter: obligations

The base law of currency regulation is Federal Law No. 173-FZ of 10 December 2003. For a Russian exporter it forms three key blocks of obligations: properly drafting the contract and registering it at the bank, ensuring revenue repatriation within the established deadlines, and timely submission of supporting documents. Each block has its own deadlines, forms, and sanctions for breach.

Contract registration (UNK / deal passport)

Any foreign-trade contract exceeding the threshold amount must be registered by the exporter at the servicing bank. As a result, the bank assigns it a Unique Contract Number (UNK) — a twelve-digit code that accompanies all subsequent operations on this contract. Until 2018 the same function was performed by the "deal passport", and in everyday usage both terms are used as synonyms, although formally, since 1 March 2018 under the new Instruction 181-I, the deal passport has been abolished and replaced by the UNK.

Registration is not an authorisation procedure. The bank does not "approve" the contract but technically registers it, assigning an identifier. The bank can refuse only on formal grounds: the contract is not signed, essential terms are missing, there is no amount or currency of obligation. Assessing commercial reasonableness is not part of the bank's tasks.

FX-revenue repatriation

This is the heart of the exporter's obligations. Article 19 of 173-FZ requires the resident to ensure receipt from non-residents on its bank accounts at authorised banks of foreign currency or the currency of the Russian Federation due for goods supplied, work performed and services rendered. The deadline is set out directly in the contract — it is an essential term, without which the bank will not register the contract.

"Repatriation" does not mean a mandatory FX sale — it concerns the physical receipt of funds on an account at a Russian bank. What to do with the revenue further (sell for rubles, hold in foreign currency, transfer to another of your accounts) is a separate question of currency regime. Until 2024 there was a requirement for the mandatory sale of a certain share of FX revenue (Decree No. 79 of February 2022); now it has largely been cancelled.

Document submission deadlines

For each operation under a registered contract, the exporter must submit supporting documents to the bank within the established deadlines. The standard deadline is 15 business days from the date of the operation; for certain document types (SPD, SVO) the deadlines may differ. The exact calendar is in Instruction 181-I; it is most convenient to keep it as an internal regulation.

Nuance on repatriation in 2024–2025. By Presidential Decree No. 771 of 11 October 2024, the requirements for the mandatory sale of FX revenue have been substantially eased: for most categories the sale threshold has been lowered to symbolic values or cancelled altogether. This does not cancel the repatriation duty — revenue must still be credited to a Russian account. For non-commodity exports and services additional concessions on deadlines are in place.

When you need a UNK and how to get one

UNK — the Unique Contract Number — is needed not for all contracts, but only for those that exceed the threshold amounts. Contracts below the threshold proceed as "no-contract operations" with a simplified document scheme: the bank verifies the invoice and the justification of the payment purpose, but without formal registration. This is convenient but has its risks — splitting payments to circumvent the threshold is covered separately below.

Thresholds for registration

The current thresholds under Instruction 181-I:

• Import contracts — from RUB 3 million (or the equivalent in foreign currency at the Bank of Russia exchange rate on the contract signing date).
• Export contracts — from RUB 10 million (or the equivalent). The separate, higher threshold for exports is connected with lower capital-outflow risks: in an export, money must come into Russia, not leave it.
• Loan agreements with non-residents — from RUB 3 million. This applies both to loans extended by a Russian resident to a non-resident and to those raised from a non-resident.

The amount is counted for the contract as a whole, not for an individual shipment. If a framework contract provides for shipments of RUB 50 million, it must be registered even if the first shipment is for RUB 500 thousand. When the price is increased through an addendum, registration becomes mandatory once the threshold is exceeded.

Registration procedure

The algorithm for the exporter has six steps, and the whole process usually takes one business day:

1. Prepare the contract. Signed by both parties, containing all essential terms (subject, amount, currency, performance deadlines, payment terms and deadlines, the parties' bank details).
2. Prepare additional documents. If the contract is in a foreign language — a translation (notarised on the bank's request), copies of the non-resident's constitutional documents (if you are working with this counterparty for the first time), a certificate of beneficial owners of the non-resident for KYC.
3. File an application with the bank. Through the remote banking system (RBS) or in branch. The application to register the contract follows the bank's form, with scans of the documents attached.
4. Wait for verification. Within one business day the bank verifies the completeness of the package and compliance with 181-I. If there are remarks — a request for revision is issued.
5. Receive the UNK. After approval the bank assigns a number to the contract and records it in the bank-control statement. The UNK is used as a mandatory attribute in all subsequent operations under the contract.
6. Pass the UNK to the counterparty. The foreign buyer must indicate the UNK in the payment purpose when transferring revenue — this is critical for the bank's correct qualification of the inflow.

When the servicing bank is changed, the UNK is reissued: the old one is closed with the statement transferred, the new one is opened at the new bank. The bank transfers the operations history; the exporter files an application and a copy of the bank-control statement from the previous bank.

For a detailed look at working with Chinese importers and arranging payments under export contracts, see the article on paying for exports from China. It covers yuan settlements, SPFS channels, and working through payment agents.

181-I: documents checklist for bank compliance

Bank of Russia Instruction No. 181-I of 16 August 2017 is the main technical document describing the procedure for residents and non-residents to submit supporting documents and information to authorised banks when carrying out currency operations. For the exporter it is the working "desk reference": it sets out operation types, document forms, deadlines, and currency-operation codes. Full text on the regulator's site: Bank of Russia Instruction 181-I.

Below is a consolidated checklist for typical exporter operations. The "Deadline" column is counted from the date of the corresponding operation (shipment, receipt of revenue, signing of an addendum). The "Document form" column indicates the standard the bank expects — most often a form from the Annex to 181-I, but analogues agreed with the bank are acceptable.

SVO (currency-operations certificate) and SPD (supporting-documents certificate) are strict forms from the annexes to 181-I with a regulated set of fields and codes. In most banks they are generated automatically in the RBS system based on the payment data — the exporter only has to verify and sign.

The bank-control statement (VBK) is the bank's internal document that aggregates the operations history under the contract: dates, amounts, currency-operation code, balance. The exporter can request a VBK extract at any time to reconcile against its own records.

Common exporter mistakes

Most violations are committed not maliciously but through inattention. The price, however, is high — fines under 15.25 of the Code of Administrative Offences are measured in percentages of the operation amount, and on large contracts run into millions of rubles. Below are the three most frequent classes of mistakes.

Payment purpose not matching the contract

The most common case — the foreign payer puts a vague wording in the payment purpose ("payment under contract"), without a reference to the UNK and a specific invoice. The bank cannot unambiguously qualify the inflow, suspends the credit, and requests documents.

The solution must be built into the contract itself: in the "Settlement procedure" section, set a mandatory condition — the buyer indicates the UNK, the invoice number and a brief description of the goods in the payment purpose (e.g. "UNK 24010001/0001/0001/2/3, Invoice INV-2026-001, equipment supply per Contract 12-2026"). On repeat payments the format is reused — the bank qualifies the inflow automatically.

Late documents under 181-I

The standard deadline for submitting SPD and other supporting documents is 15 business days from the operation date. Exporters miss this regularly: the accountant forgot, the GTD wasn't issued in time, the counterparty delays the closing acts. Each delay is a separate administrative offence under 15.25.6 of the Code of Administrative Offences, fine up to RUB 50 thousand per document for a legal entity.

Prevention is an internal regulation with reminders. The 181-I deadlines are embedded in the accounting system; the responsible person receives notifications 5 and 2 business days before expiry. For large contracts, a separate calendar of obligations linked to the UNK is kept.

Late repatriation — fines under Article 15.25 of the Code of Administrative Offences

The most expensive class of mistakes is failure to fulfil the repatriation duty within the deadline. The buyer was late paying, the exporter took no documented measures, the repatriation deadline expired — the offence under Article 15.25 part 4 of the Code of Administrative Offences is established. The fine for a legal entity is 75–100% of the uncredited amount plus 1/150 of the refinancing rate for each day overdue. For an officer — RUB 20 to 30 thousand.

There is one defence — proof of "reasonable measures" to collect the revenue: claim letters, recording violations in acts, going to arbitration, using EXIAR insurance coverage. If the measures are taken and documented, liability is removed. Before the deadline expires it is also possible to execute an addendum on extension — a lawful way to move the boundary.

What changed in 2024–2026

Currency legislation in 2024–2026 evolved along two opposing vectors: easing of the mandatory revenue sale on one side, tightening of AML control and sanctions routes on the other. For the practising exporter it is important to understand both lines.

Easing of the mandatory FX-revenue sale

Presidential Decree No. 79 of 28 February 2022 originally set: 80% of FX revenue is subject to mandatory sale on the domestic FX market within three business days. By 2023 the threshold had been lowered to 50%, then to 25%, and by Decree No. 771 of 11 October 2024 the requirements were effectively cancelled for most exporters. As of April 2026, the mandatory sale remains only for certain strategic commodity groups.

This did not cancel the repatriation duty: revenue must be credited to an account at an authorised Russian bank. But the further fate of the revenue — whether to sell, hold in foreign currency, or transfer to another of one's own accounts — has once again become the exporter's commercial decision. For businesses with FX expenses (imported components, foreign procurement) this is a significant simplification.

Changes to Instruction 181-I

The bulk of the 181-I rules over 2024–2025 remained stable — thresholds, forms, and deadlines did not change. Pinpoint amendments concerned technical aspects: new currency-operation codes for settlements in the national currencies of friendly countries, clarifications on crypto-assets within the experimental legal regime for digital financial assets (CFA), tightening of beneficiary identification of foreign counterparties under 115-FZ.

New AML requirements for exporters

Since 2024 the Bank of Russia has reinforced its methodological recommendations for countering fraudulent transfers. For foreign-trade activity, stricter criteria of "suspicious operations" have appeared: settlements with counterparties from "grey" jurisdictions, splitting of payments to circumvent the UNK threshold, atypically short or long payment terms, material divergences of the contract price from the market. Each such pattern is grounds for an extended document request and a potential refusal.

Impact of sanctions restrictions on typical corridors

Payment routes have been radically restructured. SWIFT for the largest Russian banks is blocked, correspondent relationships with Western banks are either terminated or frozen. New corridors have appeared — through banks in China, the UAE, Türkiye, Armenia, Kazakhstan, through the Bank of Russia's SPFS, through licensed payment agents. Each corridor has its currency-control specifics: additional source-of-funds documents for friendly banks, a double chain of contracts and SVOs when working through an agent. A detailed breakdown of the routes — Non-resident ruble 2026.

Frequently asked questions

1. What is a UNK and when do I need one?

UNK is the Unique Contract Number that the currency-control agent bank assigns to a foreign-trade contract upon registration. Since 2018 it has replaced the former deal passport, but the terms are often used as synonyms. A UNK is required for import contracts from RUB 3 million and export contracts from RUB 10 million; loan agreements with non-residents — from RUB 3 million. Contracts below the threshold proceed as "no-contract" operations with a simplified document flow.

2. How long is the deadline for FX-revenue repatriation in 2026?

The deadline is set in the contract itself — it is a mandatory condition under 173-FZ. For most export contracts it must not exceed "reasonable commercial" terms tied to the shipment schedule. For some categories of goods (non-commodity exports, certain categories of services) the mandatory FX-revenue sale requirement has been effectively cancelled since 2024, but the repatriation obligation — i.e. crediting the revenue to an account at an authorised Russian bank — remains.

3. Can revenue be received in rubles instead of foreign currency?

Yes. If the contract is originally denominated in rubles, the foreign buyer pays from its ruble account at a Russian bank or via a "Loro" correspondent account of a foreign bank. Since 2022 a significant share of export contracts has shifted to ruble settlements, especially with friendly jurisdictions. For currency-control purposes, a ruble payment from a non-resident is treated the same way as FX revenue and is governed by 173-FZ and 181-I.

4. What if the counterparty doesn't pay on time?

The exporter must take "reasonable measures" to collect revenue within the contractual deadline: send a formal claim, file an arbitration suit, use EXIAR insurance coverage. If the measures are taken and documented, the fine under Article 15.25 of the Code of Administrative Offences does not apply. With systematic disregard for overdue payments, the bank reports to the FNS and Rosfinmonitoring. Extending the deadline through an addendum to the contract is also permitted before the original deadline expires.

5. How does the bank choose the contract for registration?

The very term "deal passport" has been replaced by UNK — Unique Contract Number — since 2018. The bank does not "choose" it but assigns it as a result of registering the contract on the exporter's application. The number is generated automatically under the rules of Instruction 181-I and is tied to the contract for its entire term. When the servicing bank is changed, the UNK is reissued at the new bank — the old one is closed, the new one is opened with the operations history transferred.

6. What are the fines for 173-FZ violations?

The base article is 15.25 of the Code of Administrative Offences. Failure to repatriate — fine of 75–100% of the uncredited amount for legal entities, 1/150 of the refinancing rate for each day overdue. Missed deadlines for submitting supporting documents to the bank — RUB 5 to 50 thousand per document for legal entities; for repeated violations, disqualification of officers is possible. Non-compliance with the procedure for opening foreign accounts — separate offences with fines up to RUB 1 million. For particularly large evasions of repatriation — criminal liability under Article 193 of the Criminal Code.

7. Can I use a payment agent to simplify the process?

Yes, and for recurring contracts this is often economically justified. A licensed payment agent receives foreign currency from the foreign buyer abroad and credits rubles (or foreign currency) to the exporter in Russia, assembling the document set under 173-FZ and 181-I. Legally these are two separate transactions: one between the buyer and the agent, another between the agent and the exporter. The exporter receives an already "closed" payment with a ready-made document pack for the bank, without having to deal with UNK and SPD on its own. More on the scheme — on the NOOR Capital payment agent page.

8. How to prepare for a currency-control audit?

An internal audit is performed by the agent bank continuously — for every operation. An external audit is performed by the tax authority (the FNS has become the authorised currency-control body) — usually after a reporting period or upon a signal from the bank. The standard preparation pack: the contract with all addenda, the operations statement, SPD and SVO for the period, customs cargo declarations, correspondence with the counterparty about overdue payments (if any). Documents must be kept for at least three years from the date of the operation — this is the limitation period for most offences under Article 15.25 of the Code of Administrative Offences.