Update of the Foreign Legal Entities List Subject to Russian Special Economic Measures

17 November 2022
Ellina Izotkina
Senior Associate
Ksenia Skoromolova
Junior Associate

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.

The criterion for inclusion in this list was the activities of companies in the field of military-technical cooperation. All of the states which companies are included in the list have imposed sanctions on Russia. In total, the Government included 74 legal entities registered in Bulgaria, Poland, Slovakia, Germany, the UK, Lithuania, Poland, the United States, the Czech Republic, Montenegro and Estonia in the list.

Inclusion of legal entities in this list means a ban on their certain actions, as well as actions of companies controlled by them.

Such actions include:

  • Transactions involving listed companies, including entering into foreign trade contracts
  • Transactions in favor of listed companies
  • Transactions involving the call in Russian ports of ships owned and (or) chartered by listed companies, in their interest or on their behalf
  • Transactions involving payments, financial transactions, securities transactions, in which the parties or beneficiaries are listed companies
  • Fulfillment of obligations in favor of listed companies on completed transactions, if obligations are not fulfilled or not fulfilled in full

In order to obtain temporary permission to conduct certain operations with these companies, as well as companies under their control, it is necessary to file a special application with the Government through the Federal Service for Military-Technical Cooperation.