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Presidential Decree No. 193 of 25 March 2026 introduces a new special-order export regime for refined gold bullion. The operative prohibition: individuals, legal entities, and individual entrepreneurs may not export refined gold bars with a total weight exceeding 100 grams from Russian territory. The decree was adopted under the President's powers pursuant to Federal Law No. 127-FZ of 4 June 2018 (the parent counter-sanctions enabling statute, already filed) and Federal Law No. 164-FZ "On Export Control."
Permitted channels (exhaustive carve-outs):
1. EAEU-destination movements — export of refined gold bars to EAEU member-state territories (Belarus, Kazakhstan, Kyrgyzstan, Armenia) is permitted through air-border checkpoints at international airports of Vnukovo, Sheremetyevo, Domodedovo (Moscow region) and Knevichi (Vladivostok), conditional on a permit from the Federal Assay Office (Probirnaya Palata Rossii / Российская государственная пробирная палата).
2. Non-EAEU individual movements — export by physical persons to non-EAEU destinations is permitted through the same four airports, conditional on a permit from the Federal Border Service (FSB Russia, Pogranichnaya Sluzhba FSB Rossii).
The effective in-force date of 1 May 2026 provided a c.5-week implementation window from announcement to enforcement.
Stated official rationale: Deputy Finance Minister Alexei Moiseev framed the measure as anti-shadow-economy: "Gold is increasingly being used as a substitute for foreign currency in illicit transactions, fuelling capital flight and money laundering." The framing deliberately avoids explicit counter-sanctions language, positioning the decree as a financial-integrity instrument rather than a geopolitical response — mirroring the approach taken with Resolution No. 313 (2022 counter-sanctions export list) and Resolution No. 2089 (2025 grain quota).
The measure is analytically inseparable from the post-2022 Western sanctions architecture targeting Russian gold:
refineries (Krastsvetmet, Novosibirsk, Uralelectromed) from its accredited refiner list, severing Russian-refined bullion from London, CME/COMEX, and Zurich OTC markets.
ban on importing Russian-origin gold (first imposed June 2022).
oligarch-linked entities had routed physical bullion through UAE (Dubai), Türkiye, Hong Kong, and Kazakhstan to circumvent the LBMA/G7 ban. The 100-gram threshold + airport-only carve-outs effectively close that private/corporate outbound channel while leaving Bank of Russia and Gokhran (state precious-metals repository) sovereign institutional flows unaffected through established inter-central-bank settlement mechanisms.
Result: Remaining Russian gold disposal channels are concentrated into (a) Bank of Russia reserve management (USD ~140–160bn gold tranche at official prices), (b) Gokhran sovereign sales to domestic jewellery + electronics industries, (c) licensed export to EAEU counterparties through the four named airports. The net effect is increased funnelling of Russian gold supply toward BRICS-aligned counterparties (China, India) via sovereign-to-sovereign channels, with secondary-order implications for LBMA / COMEX vault inflows and London / Shanghai / Mumbai gold-price-differential dynamics.
third largest gold producer (~300–310 t/yr at LBMA-delisted refineries). Prior to the decree, private bullion outflows via UAE and Türkiye corridors provided a marginal LBMA-adjacent supply stream. Decree 193 concentrates remaining outbound supply through Bank of Russia + Gokhran sovereign channels and licensed EAEU routes, reducing the non-sovereign private-channel portion to near-zero.
post-2022 effort to build non-dollar commodity settlement architecture, the decree accelerates shift toward China / India as primary physical gold offtake counterparties via bilateral sovereign-to-sovereign channels exempt from the decree's individual/corporate prohibition scope.
Russia-issued action in the register (prior: Law 127-FZ, Resolution 506, Resolution 1400, Resolution 1544, Decree 693, Resolution 2089). It is the first Russia action directly targeting precious-metals bullion export flows, distinct from the queued Resolution N° 1947 of 28 November 2025 (which covers precious-metals waste and scrap — a different physical product class under a different legal instrument type (Постановление Правительства vs Указ Президента)).
by Bank of Russia to channel additional gold sales to EAEU counterparties (Kazakhstan, Belarus) as part of a broader reserve-rebalancing toward friendly currencies.
waste and scrap (current subject of separate Resolution N° 1947 queued for filing), consolidating the Russian bullion- export-control architecture into a unified instrument.
carve-outs as potential secondary-sanctions exposure for UAE/Türkiye/Central-Asia intermediary banks handling licensed flows under the four-airport permit regime.