The moratorium provides persons to whom it applies benefits (in particular, exemption from payment of penalties and other financial sanctions) and at the same time imposes additional restrictions on them, for example, a ban on the payment of dividends and distribution of profits.
The Central Bank of the Russian Federation commented on this clarification, noting that the ban on the payment of dividends and distribution of profits should be considered as a ban on the company from performing certain corporate actions (Letter of the Bank of Russia dated May 17, 2022 N 010-31-2 / 4257).
At the same time, banks are not obliged to control the implementation by the organization, which is subject to the moratorium on initiating bankruptcy proceedings, of the ban on the payment of dividends and distribution of profits. But banks have the right to establish in internal documents and contracts with customers additional procedures for accepting for execution orders for the transfer of funds.
