Сounter-Sanctions regime in Russia: new Official Clarifications on Decree No. 618 and new Presidential Decree No. 737

Сounter-Sanctions regime in Russia: new Official Clarifications on Decree No. 618 and new Presidential Decree No. 737

18 October 2022

In the course of regular updates on Russian counter-sanctions measures, we would like to provide you with summarized information on:

  • new Official Clarifications published[1] by the Ministry of Finance on October 14, 2022; and
  • new Presidential Decree No. 737 published on October 15, 2022.

The above have hugely updated the current counter-sanction FDI regime in Russia, in particular, new transactions requiring counter-sanctions approval were added (e.g., indirect deals with shares in Russian JSCs and transfers of 1% of shares in banks and financial institutions, etc.).

Follow the link to learn more.

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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.

Sincerely,
ALRUD Law Firm

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