On 27.03.2023 the Subcommission of the Government Commission for the Control of Foreign Investments published an Extract from the minutes of its meeting dated 02.03.2023. This document provides for a new requirement which has to be fulfilled in order to obtain Subcomission’s permission with regard to sale of shares of Russian companies. Foreigners from unfriendly states are now obliged to transfer funds to state budget in the amount of 5%-10% of the target’s valuation. 

In addition to the previously adopted rules the Sub-Commission of the Government Commission for the Control of Foreign Investments (hereinafter referred to as the "Sub-Commission") published new conditions for issuing licenses on transactions with shares (stocks) in Russian LLC and JSC conducted with persons of foreign unfriendly states.

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.

On 17 January 2023, the Decree of the President of the Russian Federation "On the temporary procedure for decision-making by the bodies of some business companies" was signed and published. It introduces several changes in decision-making for a number of large Russian companies.

On December 27, 2022, the rules for cash settlements between residents and non-residents came into force.

Until the end of 2023, special rules have been extended for transactions on acquisition or lease of additional retail space for trading by entities engaged in food retail through the organization of a retail network.

On 19 December 2022, Federal Law “On Amendments to Certain Legislative Acts of the Russian Federation and Suspension of Certain Provisions of Legislative Acts of the Russian Federation” extending previously introduced economic measures and establishing a number of anti-crisis innovations was published.

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.

The President signed the Decree which introduces additional restrictions on transactions with persons from “unfriendly” states.