In reply to economic and financial sanctions within the last 15 months the Russian state has introduced various restrictions for persons from ‘unfriendly’ states. These limitations also affected their corporate rights in Russian companies – disposal of shares, receipt of dividends and other aspects of corporate management. 

The High Court of Justice on March 3, 2023 ruled on the dispute between UniCredit Bank (UK) and aviation companies Celestial Aviation Services Limited (Ireland, a subsidiary of AerCapHoldings N.V. (Netherlands)) and Constitution Aircraft Leasing (Ireland) on the issue of payment of funds under letters of credit of Sberbank.

New alert was released jointly by OFAC, BIS and DOJ on March 02, 2023 on suspicions third parties transactions under Ukraine-Russia restrictions. Another list of criteria was introduced that should help to identify and ‘aggressively prosecute’ those who violate U.S. sanctions and export control laws.

Arbitrazh court for the Moscow City issued a judgement under the claim of a Russian entity to Alfa-Bank JSC. By this decision the court ordered the Russian bank to make a refund of the frozen funds allocated on the accounts of a correspondent bank to its client as well as charged the bank with penalties and interest for the use of its client’s money.

On February 6, 2023, the EU official journal published news about delisting Dmitry Ovsyannikov, the former governor of Sevastopol, from the sanctions list. The exclusion was preceded by the decision of the EU court of 26 October 2022 following the review of Ovsyannikov's appeal.

On 8 February 2023 Alexey Repik, the founder of R-Pharm – Russian pharmaceutical company, producing, among other things, drugs for COVID-19 (e.g. coronavir (favipiravir) and artlegia (olokizumab)) was listed in the UK Sanctions List.

Reasoning behind this decision is that he holds the position of the Chairman of the Board of R-Pharm, which receives financing from the Russian Direct Investment Fund – a Government of Russia-affiliated entity. Moreover, Alexey Repik is also designated as a person associated with Vladimir Putin, the Russian President.

The new General license No 6C published by OFAC on January 1, 2023, establishes exceptions from US sanctions related to the spheres of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices.

The Government approved amendments to the Decree No. 851 dated 11.05.2022, updating the list of legal entities of foreign states, in respect of which special economic measures are applied.

In October 2022, the European Commission approved the eighth package of sanctions against Russia. Among other restrictions it established a ban on the provision of legal services to Russian companies. A few weeks later, on October 24, the European Commission published answers to frequently asked questions including explanations as to what kind of legal services fall under the ban and whether the extension of sanctions to this sphere does not entail restrictions on the right to protection.

Under the Presidential Decree No 756 dd 19.10.2022 in accordance with the Law on Martial Law Status martial law is introduced in Donetsk and Luhansk Republics, Zaporozhye and Kherson Regions starting from 20.10.2022.