The Russian President signed the Decree imposing a requirement to make payments under agreements for using exclusive rights in favor of foreign rightholders from non-friendly states, as well as a number of Russian rightholders, including those supporting sanctions, only through a special ruble account opened in an authorized bank.

Obtaining information on real estate owners and transferring data abroad could get substantially more difficult. Let’s have a look at amendments to the Personal Data Law.

The Russian Central Bank published new explanations on application of the Presidential Decrees dealing with anti-sanctions measures.The most notable ones seem to be the Central Bank’s comments about the procedure for applying the limit of RUB 10 million on obligations to foreign creditors pursuant to Clause 2 of Presidential Decree No.95.

On May 04, 2022, Presidential Decree No.254 was published, under which Presidential Decree No.95 starts to apply to dividend payments from limited liability companies, partnerships and cooperatives to residents of non-friendly states and entities they control (unless they are registered in Russia).

On April 12, 2022, Draft Law No.104796-8 “On external administration for managing a company”  was introduced to the State Duma of the Russian Federation. The Draft Law allows external administration of companies with non-friendly foreign participation of at least 25%.

Today, when legislative requirements are changing every day and new foreign currency restrictions are replacing “old” new restrictions introduced only a week ago, it is crucial to plan your activities very carefully with the current requirements in mind and to analyze not only current, but also potential risks, while fighting the headwinds to the extent possible

In the first half of March 2022, the list of Russian “anti-sanctions” measures changed significantly. Current acts of the Russian state authorities in this area are aimed at solving two key tasks, namely, reducing the outflow of foreign currency from the Russian banking system and limiting the exit of foreign investors from Russian assets.

In early March, numerous legislative changes, restrictions and bans were introduced. However, it can be said without exaggeration that sanctions and anti-sanctions in the area of foreign currency regulation raised the greatest number of concerns.

On March 1, 2022, Presidential Decree No.81 “On additional economic measures for ensuring financial stability of the Russian Federation” was published, which adopted new prohibitions and made some adjustments to the measures adopted earlier.

Uneasy times have arrived, and various sanctions from the US, EU and UK against individuals and Russian companies, in particular, related to banking, as well as foreign-currency anti-sanctions are cause for apprehension when considering the thought of having disposition over assets in Russia and abroad.