Changes to the Rules Governing Cross-Border Transfers of Personal Data
16 July 2026
We would like to inform you that the Russian Parliament passed a law amending Article 12 of Federal Law № 152-FZ “On Personal Data” (the “Law”).
The amendments revise the approach to determining which foreign states are deemed to provide adequate protection of the rights of personal data subjects.
The amendments will enter into force on the date of the Law’s official publication. The Law is currently awaiting the President's signature.
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Note: please be aware that all information provided in this letter is based on an analysis of publicly available information as well as our understanding and interpretation of legislation and law enforcement practices. Neither ALRUD Law Firm nor the authors of this letter bear any liability for the consequences of any decisions made in reliance upon this information.
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Sincerely,
ALRUD Law Firm
Lesnaya st., 7, 12th fl., Moscow, Russia, 125196T: +7 495 234 96 92, T: +7 495 926 16 48, info@alrud.comwww.alrud.ru