RUSSIAN LAW SUMMARIES

 

By Secretan Troyanov

 

No. 7 (35)

 

March 15, 2001

 

 

RUBLE ACCOUNTS FOR NON-RESIDENTS

 

(NEW REGULATIONS)

 

 

The Central Bank of Russia has recently introduced new rules for ruble accounts of foreign individuals and corporations with Russian banks (Instruction No. 93-I “On the procedure for opening bank accounts of non-residents in the currency of the Russian Federation with authorized banks and the conduct of operations through these accounts” of October 12, 2000, officially published in the Central Bank Bulletin on December 7, 2000, which entered into force on March 7, 2001).

 

BACKGROUND AND CONCEPT:

 

While the Civil Code defines the contractual relationship between banks and accountholders, the Bank of Russia (hereafter “Central Bank” or “CBR”) as the authority responsible for banking supervision and monetary policy is empowered to regulate all technical aspects of the operation of bank accounts by Russian banks. Simultaneously the federal law on currency regulation and exchange control gives it authority to regulate accounts maintained by foreign individuals and corporations within Russia. Instruction 93-I is almost exclusively concerned with exchange control.

 

Today’s exchange control system is essentially twofold:

 

-                     Basically only payments for the export or import of goods, services and intellectual property may be made in foreign currency. Today import, respectively export, means a cross-border transaction and in the majority of cases a cross-border payment. The Central Bank monitors such payments mainly at their source, i.e. at the end of the Russian corporation acting as importer or exporter under the respective foreign trade contract and the Russian bank servicing the latter’s foreign currency accounts.

 

-           Foreign corporations or their Russian branches (representative offices) may receive or make payments in Russian currency in relation with both cross-border and domestic transactions. Most contracts performed within Russian territory and local expenses (lease payments, salaries, etc.) must be settled in rubles. The capability of opening and maintaining ruble accounts is therefore a prerequisite for the conduct of business in Russia. As the Russian ruble is not freely convertible, payments in the national currency indeed always imply the use of Russian bank accounts. The Central Bank can therefore control such payments and their impact on the country’s balance of payments by regulating the operation of ruble accounts maintained by foreign individuals and corporations (including correspondent accounts of foreign banks) and restricting the convertibility into foreign currency and subsequent repatriation of ruble revenues received in such accounts.

 

Instruction 93-I replaces Instruction No. 16 of July 16, 1993 (“Instruction 16”), pursuant to which foreign corporations could maintain two types of ruble accounts, namely so-called “T”- or Trading Accounts and “I”- or Investment Accounts. Initially the conversion and transfer abroad of rubles held in Trading Accounts was not possible. This changed when Russia adhered to Article VIII of the IMF Articles of Association and the Central Bank consequently amended Instruction 16 (Central Bank Order No. 02-196 of May 28, 1996). However, the crisis in August 1998 showed that this had opened a loophole for capital flight, and the law on currency regulation and exchange control was amended on December 29, 1998 to allow the Central Bank to monitor payments in the national currency between residents and non-residents.

 

By issuing Instruction 93-I the Central Bank proceeds to a general overhaul of the previous system on the basis of experience accumulated since 1993. Trading Accounts will be replaced by “N”-accounts (“N” standing for “non-convertible”), Investment Accounts by “K”-accounts (“K” standing for “convertible). Accounts maintained by individuals will forthwith be named “F”-accounts (“F” standing for “physical person”). “F”-accounts, contrarily to “K” and “N”-accounts, may not be used for business and investment. Accounts may be opened only with so-called “authorized banks”, i.e. banks licensed to conduct operations with foreign currency.

 

The new rules will become effective by June 7 of this year, but as from March 7 banks are no longer authorized to open “I”- and “T”-accounts in accordance with Instruction 16. Existing accounts remain operational until June 7, when remaining balances will have to be transferred to “N” and “K”–accounts respectively (Central Bank Regulations No 126-P of October 12, 2000) or converted into foreign currency. It remains unclear whether holders of Trading and Investment Accounts must resubmit complete documentation for the opening of “K” and “N”-accounts in accordance with Instruction 93-I, but basically we expect this to be the case. One of the main purposes of the new Instruction is certainly the cleansing of existing ruble accounts, many of which have not been used for years but have remained in the books and statistics of Russian banks.

 

There also exist so-called “S”-accounts which were introduced in 1997 to make it possible for non-residents to invest in government treasury bonds. These accounts still function and do not fall under Instruction 93-I (CBR Instruction No. 79 of March 23, 1999).

 

“N”-/ “K”-ACCOUNTS:

 

The initial concept of the Trading and Investment Accounts was relatively simple. Investment Accounts could be used to make and receive payments in relation with investments as defined by the legislation on foreign investments (privatization deals, purchase and sale of shares in Russian companies, etc.). Trading Accounts could be used to make and receive payments related to commercial transactions and to meet business expenses (rental payments, salaries, etc.). While Investment Accounts were fully convertible, Trading Accounts were not. However, certain categories of revenues did qualify for transfer from the Trading to the Investment Account and subsequent conversion into foreign currency. This allowed the Central Bank to implement:

 

-                     the broad guarantees with respect to the repatriation of investments and investment revenue which Russia has granted to foreign investors under domestic investment law and bilateral investment treaties;

-                     Article VIII of the IMF Articles of Association pursuant to which national exchange control regulations can not restrict money transfers abroad in relation with current payments (payments for imports and exports, short-term credit facilities).

 

Payments deemed outside these categories were subject to restrictions: either they could not be made in the national currency or ruble proceeds therefrom could not be converted and repatriated. One of the disadvantages of the former regulations was the fact that the lists of permitted payments to and from Trading and Investment Accounts were exhaustive. Transactions which did not fall into one of the categories listed were prohibited. Instruction 93-I now divides all payments into six groups:

 

-                     Group 100 – forex transactions;

-                     Group 200 – payments for the delivery of goods and services;

-                     Group 300 – financial transactions;

-                     Group 400 – non-commercial payments;

-                     Group 500 – other payments between residents and non-residents;

-                     Group 600 – transfers between accounts of non-residents.

 

Each group comprises a list of authorized payments and specifies for each category of payments which type of account may be credited or debited (see attached schedule for a list of payments permitted to and from each of the accounts). Payments between residents and non-residents which are not explicitly attributed to Groups 100 – 400 form Group 500. Such payments may be made from “K”-accounts and received in “N”-accounts. Each category of payments is given a three-figure numeric code. Transfer instructions which the client remits to the bank must contain a reference to this code (e.g. “201KNF receipt of payment for goods under the contract No…”). Banks are not allowed to execute transfer instructions in the absence of this reference.

 

Each non-resident may open an unlimited number of “K”, “N” and “F” accounts with one or several authorized banks (earlier the number of accounts was limited). Ruble payments between non-resident accounts are not restricted except that ruble transfers from one “N”-account may be made only in favor of another “N”-account. This is a very important innovation since transfers between “I”-accounts were prohibited (it is interesting to note that the Central Bank has very recently announced its intention to allow transfers between “S”-accounts also). Practically this means that ruble proceeds subject to repatriation restrictions may be assigned to other non-residents.

 

Restrictions apply mainly to rubles held in “N”-accounts, which may be used exclusively for the purposes specified in Instruction 93-I and may be converted into foreign currency only following a special procedure providing for a one-year waiting period during which the amounts marked for conversion remain blocked. Nevertheless “N”-accounts will make it possible to receive in rubles payments which are not authorized in foreign currency without Central Bank permission. This is a valid alternative in cases where it is difficult or impossible to obtain the necessary Central Bank permit for the payment of hard currency. In cases of doubt it may even be advisable to include a clause in contracts to the effect that residents must make payments in rubles should it appear impossible to pay in foreign currency. This could help avoiding disputes (contracts infringing exchange control regulations can be invalidated).

 

Instruction 93-I brings ruble payments between residents and non-residents in line with foreign currency payments, i.e. most payments which may be made in foreign currency because they are either related to current transactions as defined by the law on currency regulation and exchange control or have been authorized by the Central Bank (e.g. Central Bank Order 02-94 of April 24, 1996) can now alternatively be made in rubles. The reverse is not the case, i.e. a series of payments (in the attached schedule marked in italics) can be made exclusively in rubles unless CBR permission is obtained on a case-by-case basis. This concerns, in particular, payments related to investments (shares, equity in Russian companies) and real estate (including leases). In certain areas Instruction 93-I liberalizes exchange control (e.g. ruble loans may be granted by non-residents without restrictions).

 

Instruction 93-I also regulates the use of ruble cash. It confirms that the limit on cash payments (10,000 RUR or approx. 350 USD) applies to resident and non-resident corporations alike. Payments in excess of this limit must be made by bank transfer. Total cash holdings of non-resident accountholders may not at any given time exceed a specific amount defined by the bank operating the account, which also has the obligation to monitor the cash operations made by its client. Ruble cash may be withdrawn:

 

-                     from both “K” and “N”-accounts for the payment of salaries and other compensation to employees, the payment of travel and small current expenses (code 209) and the payment of consular fees (code 412);

-                     from “K” correspondent accounts of foreign banks for the export of cash in conformity with the procedure defined by the Central Bank, Ministry of Finance and Customs Committee (code 320).

 

 

Cash may be deposited:

 

-                     in both “K” and “N”-accounts to remit cash holdings in excess of the limits set by the Central Bank (code 210);

-                     in “K”-accounts out of proceeds from the sale of goods and services to individuals within Russia including proceeds received from Russian legal entities from the sale under agency agreements of transport documents issued by foreign transporters (code 211);

-                     in “K” correspondent accounts of foreign banks as concerns cash imported in conformity with the procedure defined by the Central Bank, Ministry of Finance and Customs Committee (code 319);

-                     in “K”-accounts as concerns consular fees (code 411).

 

Besides the account documentation usually required under Russian law foreign corporations (legal entities) must submit the following documents when opening an account:

 

§         documents confirming the existence of the foreign legal entity (e.g. statutes, articles of association, by-laws, certificate of incorporation, excerpt from Commercial Register, etc.);

§         copy of the regulations of the branch or representative office of the foreign legal entity in Russia if the account is opened by such branch or representative office, power of attorney issued in favor of the director of the branch or representative office.

 

These documents must be submitted in notarized copies, foreign documents must be legalized by the Russian Embassy (Consulate) or, where applicable, by apostille. All documents must be in Russian or accompanied by a certified Russian translation. In addition signature cards must be legalized by a Russian notary. Under Article 86 of the Tax Code the bank must further require submission of the accountholder’s Russian tax registration certificate. Tax registration of foreign entities is regulated by an Order of the Tax Ministry No. AP-3-06/124 of April 7, 2000. If the entity is registered only in connection with the opening of an account, it must register with the tax inspection of its bank and submit a document from the tax authority of its home country confirming its tax registration and taxpayer number.

 

“N” and “K”-accounts may also be opened by individuals who submit the same documents as for “F”-accounts (see below). In this case tax registration is normally not required.

 

All authorized payments may be made either through “N”- or “K”-accounts opened in the name of the non-resident creditor or debtor of the payment or through “N”- and “K” correspondent accounts of foreign banks on behalf of their clients. Under Instruction 16 correspondent accounts could not be used for those payments which had to be made through Investment Accounts. Instruction 93-I now allows foreign banks to make any client payment through its “N”- or “K”- correspondent account provided the payment could have been made through an “N”- or “K”-account opened in the name of the client with a Russian bank.

 

 

“F”-ACCOUNTS:

 

“F”-accounts may be opened by foreign nationals essentially for non-commercial purposes (see attached schedule for a list of permitted transfers from and to “F”-accounts). Rubles held in “F”-accounts are convertible into foreign currency.

 

Individuals may withdraw cash without limitations, and payments in cash rubles between individuals (residents and non-residents) are not subject to any restrictions as long as they are not related to commercial or investment activity. When making cash deposits in the bank account, the accountholder must submit documentary evidence on the source of revenue except for amounts below 30 minimum monthly salaries per day (currently RUR 3,000 or approx. USD 100). Residents may transfer money to the “F”-accounts of non-residents without submitting any documents confirming the purpose of the payment as long as transfers do not exceed 500 minimum salaries on the value date (currently RUR 50,000 or approx. USD 1,750).

 

Any non-resident may open “K”, “N” and/or “F”-accounts (under Instruction 16 Trading Accounts could not be opened in the name of individuals). The accountholder must submit his passport, entry visa (where required for travel to Russia) and fill in a form in accordance with Instruction 93-I. It is, however, not entirely clear which individuals are deemed Russian residents. In practice foreign nationals will most probably continue to be considered non-residents if they are in Russia based on a visa, i.e. do not have a residence permit (вид на жительство). Russian nationals will most probably be deemed resident if they have a “propiska” (address stamp in domestic passport).

 

EXCHANGE CONTROL:

 

A new requirement is that payments by residents in favor of non-resident accounts be made only from accounts maintained with authorized banks (banks licensed to transact business in foreign currency and rubles), which are so-called “agents of exchange control”, i.e. under an obligation to ensure client compliance with exchange control regulations. The reverse does not apply, i.e. payments by non-residents in favor of residents may also be made to accounts maintained with other than authorized banks.

 

Authorized banks must control the following operations:

 

1)                  transfers by debit of resident accounts in favor of “N”, “K” and “F”-accounts;

2)                  transfers by debit of “N”, “K” and “F”-accounts in favor of resident accounts;

3)                  transfers between “N”, “K” and “F”-accounts;

4)                  withdrawal of cash from “N” and “K”-accounts, deposit of cash in “N”, “K” and “F”-accounts.

 

In other words the responsibility to ensure compliance with Instruction 93-I lies on the bank which makes the ruble payment, not on the bank which receives it. The bank must obtain from its client – in addition to the transfer instruction (which, as indicated above, must contain a reference to the code of the operation) – documentation confirming the purpose of the transfer (copies of contracts, etc. certified by the signature of the client).

This requirement does not apply:

 

-                     for payments made by the authorized bank in execution of its own obligations towards the non-resident accountholder;

-                     for transfers by residents in favor of “N” and “K”-accounts of amounts which do not exceed 500 minimal monthly salaries, which currently corresponds to an amount of 50,000 RUR (approx. 1,750 USD);

-                     for transfers by residents in favor of “F”-accounts of amounts which do not exceed 30 minimal monthly salaries, which currently corresponds to an amount of 3,000 RUR (approx. 100 USD);

-                     for transfers listed under point 2 and 3 above.

 

Cash may be withdrawn from and paid to “N” and “K”-accounts in accordance with applicable legislation on cash operations. If the bank receives a payment in violation of Instruction 93-I or if more than 3’000 minimal salaries are credited to an “F”-account, the bank must notify the Central Bank territorial department (ie. if the monthly amount transferred to an “F”-account exceeds what was indicated by the client when the account was opened). All documentation must be kept during five calendar years.

 

Non-residents and authorized banks incur penalties for infringements of Instruction 93-I. Banks are, however, not obliged to make inquiries concerning the economic background of the operation. The client is sole liable if he submits counterfeit documents or false information.

 

By Markus Schaer

 

 

Attachment: Schedule of permitted payments

 

 

*    *    *

 

 

 

The material in this newsletter discusses in a general way certain elements of Russian law. It is not a legal opinion.

 

The information provided herein reflects our analysis of the legal situation as at the date when the present document was published.

 

We therefore recommend that our readers seek special advice before making decisions in concrete cases.

 

Payments which may be debited from both “N”- and “K”- accounts

Payments which may be credited to both “N”- and “K”-accounts

 

 

·         (code 203) payments to Russian residents for goods purchased excluding real estate and securities (excludes import-export transactions);

·         (code 206) payments to Russian residents for services, work, intellectual property rights, information or the lease of movable property (contract performance within Russia);

·         (code 213) payments to Russian residents for the purchase or lease of real estate located in Russia;

·         (code 302) loans extended to Russian residents;3)

·         (code 303) bank deposits made with authorized Russian banks;4)

·         (code 306) interest on loans obtained from Russian residents, (code 308) repayment of loan principal;3)

·         (code 310) payment to Russian residents of dividends and coupon interest on securities issued by the accountholder, as well as of income from equity held by the Russian resident;1)

·         (code 312) payments to Russian residents under insurance contracts concluded in favor of the latter;2)

·         (code 316) payments to Russian residents for the purchase (redemption at maturity) of securities excluding shares and promissory notes / bills of exchange, payments to Russian residents under transactions with financial instruments (futures, derivatives) including related guarantee and margin deposits and similar;

·         (code 318) payments to Russian residents for the purchase (payment at maturity) of promissory notes and bills of exchange;

·         (code 321) banking commissions paid to the authorized Russian bank where the account is maintained;4)

·         (code 402) payment to Russian residents of taxes, duties, etc. excluding consular fees;2)

·         (code 404) payment of damages and penalties;1)

·         (code 408) payment of membership fees to non-profit corporations, payments for the participation in sport, cultural and similar events, in symposiums and conferences;2)

·         (code 410) payment to Russian resident individuals of salaries, royalties and other contractual remuneration;5)

·         (code 417) payment in favor of Russian residents of amounts awarded by judgements and decisions of courts and other competent authorities, of court, arbitration, notarial and other administrative fees.2)

 

·         (code 101) ruble proceeds from forex transactions with authorized Russian banks;

 

 

 

 

 

 

 

 

·         (code 212) payments from Russian residents for the sale or lease by the accountholder of real estate located in Russia;

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

·         (code 322) interest paid on amounts held in the account by the authorized Russian bank where the account is maintained.4)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Payments which may be debited only from “K”-accounts

Payments which may be credited only to “K”-accounts:

·         (code 102) payments for the purchase of foreign currency from Russian authorized banks;

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

·         (code 314) payments made to Russian residents for shares and other participations in the equity of Russian legal entities;

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

·         (code 406) payment of alimonies, pensions, inherited assets, subsidies, gifts and donations;

·         (code 415) payments made for transactions and cash withdrawals settled by credit card;

·         (code 502) all payments which do not fall into one of categories of Groups 100 – 400.

 

 

 

·         (code 201) payments from Russian residents for the delivery of goods by the accountholder (excluding real estate and securities) provided the period between the prepayment and delivery does not exceed 90 days1) or delivery precedes payment2);

·         (code 204) payments from Russian residents for services, work, intellectual property rights, information supplied by the accountholder (excluding real estate and securities) provided the period between the prepayment and contract performance does not exceed 90 days1) or delivery precedes contract performance2);

·         (code 211) proceeds (including cash) from the sale of goods and services to individuals within Russia including proceeds from legal entities from the sale of transport documents issued by foreign transporters under agency agreements;

·         (code 305) interest on loans3) and bank deposits paid by Russian residents4);

·         (code 309) dividends, coupon interest on securities, income from equity in Russian legal entities paid by Russian residents;

·         (code 311) payments from Russian residents under insurance contracts concluded in favor of the account holder;

·         (code 313) payments from Russian residents for shares and other equity in Russian legal entities purchased from the accountholder, proceeds from the liquidation of Russian legal entities;

·         (code 401) refund by Russian residents of taxes and other duties excluding consular fees;

·         (code 403) payment by Russian residents of penalties and damages;1)

·         (code 407) payment by Russian residents of membership fees to non-profit corporations, payments for the participation in sport, cultural and similar events, in symposiums and conferences;2)

·         (code 411) consular fees paid by Russian residents;

·         (code 416) payment in favor of Russian residents of amounts awarded by judgments and decisions of courts and other competent authorities, of court, arbitration, notarial and other administrative fees;2)

 

 

 

 

 

 

 

 

Payments which may be debited only to “N”-accounts:

Payments which may be credited only to “N”-accounts:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

-

·         (code 202) prepayments from Russian residents for the delivery of goods by the accountholder (excluding real estate and securities) provided the period between the prepayment and delivery exceeds 90 days;6)

·         (code 205) prepayments from Russian residents for services, work, intellectual property rights, information supplied by the accountholder (excluding real estate and securities) provided the period between the prepayment and contract performance exceeds 90 days;6)

·         (code 301) loans from Russian residents;3)

·         (code 315) payments from Russian residents for the purchase (redemption at maturity) of securities excluding shares and promissory notes / bills of exchange, payments from Russian residents under transactions with financial instruments (futures, derivatives) including related guarantee and margin deposits and similar;

·         (code 317) payments to Russian residents for the purchase (payment at maturity) of promissory notes and bills of exchange;

·         (code 501) all payments which do not fall into one of categories of Groups 100 – 400;

·         (code 601) transfers from “N”-accounts.

 

Payments which may be debited only from the type of account previously credited:

Payments which may be credited only to the type of account previously debited:

·         (code 208) repayment to Russian residents of amounts received in payment of goods, services, work, intellectual property rights, information, leases pursuant to the termination of the contract or to the non-performance or undue performance of obligations thereunder.2)

 

 

 

·         (code 207) repayment from Russian residents of amounts received in payment of goods, services, work, intellectual property rights, information, leases pursuant to the termination of the contract or to the non-performance or undue performance of obligations thereunder;2)

·         (code 304) reimbursement of bank deposits by Russian authorized banks;4)

·         (code 307) repayment of loan principal by Russian resident borrower.3)

 

1)              considered current payments under the law on currency regulation and exchange control, i.e. possible in foreign currency without Central Bank permission (import and export of goods require deal passports, cf. CBR Instructions 86-I and 91-I of October 10, 1999 and October 4, 2000 respectively, import and export of services and intellectual property rights in excess of 10,000 USD an expert opinion of the Federal Service for Foreign Currency and Economic Control, cf. CBR Directive 519-U of March 22, 1999)

2)              considered a capital payment under the law on currency regulation and exchange control, but normally permitted in foreign currency pursuant CBR Order No. 02-94 of April 24, 1996

3)              considered current transactions if for less than 180 days, capital transactions if for more than 180 days (for the latter cf. Central Bank Letter 527 of October 6, 1997), interest, repayment of principal authorized in foreign currency if loan itself authorized

4)              authorized banks do not need authorizations for transactions in foreign currencies related to their banking activity

5)              salaries and other non-commercial payments may be made in foreign currency if paid from abroad to the Russian account of beneficiary

6)              considered capital transactions which require CBR permission to be made in foreign currency

 

“F”-Accounts

Debits

Credits

·         payments for the purchase of foreign currency from Russian authorized banks (code 102);

·         bank deposits made with authorized Russian banks (code 303);

·         payments to Russian residents under insurance contracts concluded in their favor (code 312);

·         banking commissions paid to the authorized Russian bank where the account is maintained (code 321);

 

 

·         payment to Russian residents of taxes, duties, etc. excluding consular fees (code 402);

·          

·         payment of damages and penalties (code 404);

·         payment of alimonies, pensions, inherited assets, subsidies, gifts and donations (code 406);

·         payment of membership fees to non-profit corporations, payments for the participation in sport, cultural and similar events, in symposiums and conferences (code 408);

·         payment of consular fees (code 412);

·         payments by the accountholder to residents in relation with the purchase of goods, work, services for personal, family and other usage not connected with commercial or investment activity and the acquisition of rights to real estate (code 413);

 

·         payments using credit cards (code 415);

·         payment in favor of Russian residents of amounts awarded by judgements and decisions of courts and other competent authorities, of the court, arbitration, notarial and other administrative fees (code 417);

·         cash withdrawals;

 

·         transfers to “N”, “K” and “F”-accounts.

·         ruble proceeds from forex transactions with authorized Russian banks (code 101);

 

·         reimbursement of bank deposits by Russian authorized banks (code 304);

·         payments from Russian residents under insurance contracts concluded in favor of the accountholder (code 311);

·         interest paid on amounts held in the account by the authorized Russian bank where the account is maintained (code 322);

·         payment by Russian authorized banks of interest accrued on deposits (code 323);

·         refund by Russian residents of taxes and other duties excluding consular fees (code 401);

·         payment by Russian residents of penalties and damages (code 403);

·         payment by Russian residents of alimonies, pensions, inherited assets, subsidies, gifts and donations (code 405);

·         payments by Russian residents of salaries and other compensation under employment agreements, royalties and other contractual remuneration (code 409);

 

·         refund by Russian residents to non-resident individuals of payments in relation with the purchase of goods, work, services for personal, family and other usage not connected with commercial or investment activity and the acquisition of rights to real estate (code 414);

 

·         payment in favor of Russian residents of amounts awarded by judgements and decisions of courts and other competent authorities, of the court, arbitration, notarial and other administrative fees (code 416);

·         deposit of cash earlier withdrawn from the “F”-account or brought to Russia (code 418);

·         transfers from “K” and “F”-accounts (code 604, 607).