Author

Maxim Kuznechenkov

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On May 11, 2022, the Russian Government adopted Decree No. 851 “On measures to implement Presidential Decree No. 252 dated May 3, 2022” (“Decree No. 851”). Decree No. 851: (i) introduced the list of designated persons; and (ii) supplemented the list of prohibited transactions with designated persons. The list of designated persons includes 31 energy companies incorporated in the EU, the US, the UK, Singapore and Switzerland. Notably, most of the designated persons are members…

On 8 April 2022, a draft bill on nationalization of assets belonging to persons associated with “unfriendly” states (“Bill”) was submitted to the Russian State Duma. The Bill defines persons associated with “unfriendly” states very broadly to include foreign citizens and legal entities, their beneficiaries, affiliates and persons under their control. The Bill allows nationalization of all kinds of assets owned by such persons as of 24 February 2022 and located within Russia, including real…

The text of a draft bill criminalizing compliance with anti-Russian sanctions started circulating via unofficial sources on April 5, 2022. According to the media, it was submitted to the Russian State Duma (lower chamber of Parliament) on April 4, 2022. Currently, Article 201 of the Russian Criminal Code “Abuse of Authority” provides for liability of executives of companies who (a) use their authority against the company’s interests and (b) receive personal gains for themselves or…

From 2 March 2022, Russia introduced special rules for real estate transactions with foreign legal entities and individuals associated with foreign states that adopted measures targeting Russian legal entities and individuals (“Foreign States”): Russian residents may carry out transactions resulting in the change of ownership of real estate assets with (a) the counterparties from the Foreign States and (b) with persons, including Russian and non-Russian legal entities, controlled by such counterparties, only upon obtaining a…