On May 4, 2022, Russian President adopted Decree No. 254 “On interim procedures for the fulfilment of corporate finance obligations towards certain foreign creditors” (“Decree”). The Decree (1) established new restrictions on distribution of profits by limited liability companies, such as, for example, distribution of dividends (before this, the limitation only applied to distribution of dividends by joint stock companies); (2) clarified the application of some of the previously adopted restrictions. New restrictions on distribution…
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…
In this uncertain time, some global companies are announcing that they are “leaving Russia.” What does it mean to “leave Russia,” and what are the data privacy implications of doing so? Setting aside the broader business, political, and other legal considerations, the following are some initial thoughts on these challenging and rapidly developing data privacy issues. What does it mean for a global company to “leave Russia”? The specifics of the answer to this question…