Yesterday was issued Presidential Decree No. 618 (the “Decree”), which limits the ability to carry out transactions with LLC equity interests for the some categories of persons.

We kindly remind everyone that the deadline for filing a notice of participation in a Multinational Enterprise Group or 2021 is approaching. The deadline date is August 31, 2022.

On July 5, the President signed a new anti-sanctions decree No.430 (the “Decree No.430”), which eases the existing restrictions in currency regulation, but also introduces some new ones.

The Russian Central Bank has allowed payments for shares in, and contributions to, the property of non-residents without a special permit, if the relevant funds are deposited in rubles or in the currency of a friendly state.

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).

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 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.

Finally, on January 27, 2022, the Russian Ministry of Digital Development published Letter No.P11-2-05-200-3571 with explanations and examples defining the meaning of “adaptation” and “modification.”

Earlier, we wrote about the new law “on landing” foreign IT companies, under which some of them must open a representative office, branch or separate legal entity in Russia starting January 1, 2022. Based on this law, on November 22, Roskomnadzor published a list of such companies, which currently includes Google, Apple, Meta Platforms (aka Facebook), Twitter, TikTok, Telegram, Zoom, Likeme, Viber, Discord, Pinterest, Spotify and Twitch.