1.

Decree No. 193 of the President of the Russian Federation dated 25 March 2026 "On the Special Procedure for the Export of the Cash Currency of the Russian Federation and Refined Gold in Bars from the Russian Federation"

The Decree establishes restrictions on the export of the cash currency of the Russian Federation (in other words, cash roubles) from the Russian Federation to the member states of the Eurasian Economic Union, the Republic of Azerbaijan, the Republic of Tajikistan and the Republic of Uzbekistan by individuals in an amount that exceeds RUB 1 million, by legal entities and individual entrepreneurs, regardless of the amount, as well as restrictions on the export of refined gold in bars weighing in total over 100 grammes.

2.

Decision No. PRG-43-11/1199 of the Working Group of the Bank of Russia dated 1 June 2026 "On Considering Matters arising from the Issue of Permits for the Performance (Execution) of Operations (Transactions) in respect of which Prohibitions (Restrictions) Have Been Established on Their Conclusion in Connection with the Unfriendly Actions of Foreign States"

The maximum permissible volume of operations regarding the payment of participation interests, contributions and units in the property (the charter capital or joint capital, units in the asset fund of a cooperative) of non-resident legal entities, as well as regarding the payment of a contribution by residents to non-residents within the framework of the performance of simple partnership agreements through capital investments (joint venture agreements) being concluded by residents, has been increased to RUB 30 million. At the same time, effective 1 July 2026 the aggregate volume of a resident’s operations being concluded in favour of one non-resident legal entity, taking into account the operations that it concluded in favour of this entity, must not exceed the aforementioned limit from 1 April 2024.

3.

Decree No. 377 of the President of the Russian Federation dated 1 June 2026 and Decree No. 550 of the President dated 4 August 2026 on the Introduction of Amendments to Decree No. 95 of the President of the Russian Federation dated 5 March 2022 "On the Temporary Procedure for the Performance of Obligations to Certain Foreign Creditors" 

Decree No. 377 of the Russian President dated 1 June 2026 applies a temporary procedure for the performance of the obligations stipulated by Decree No. 95 dated 5 March 2022 to the operations of persons from unfriendly states on bank deposits. We wrote on this issue in our newsletters - please click on this link.

Decree No. 550 of the Russian President dated 4 August 2026 exempted the following assets of persons from unfriendly states from the temporary procedure:

•

Bank deposits contributed by individuals;

•

Bank deposits contributed by the branches, permanent establishments and other standalone or independent structural subdivisions of organisations if the Russian Federation is the place where such branches, permanent establishments and subdivisions were registered.

4.

"Thematic Review of the Supreme Court of the Russian Federation No. 8/2026. On the Application by Commercial Courts of Legislation on Special Economic Measures Stipulated for the Protection of the National Interests of the Russian Federation", approved by Judgment No. 11A/2026 of the Presidium of the Supreme Court of Russia dated 17 June 2026)

As a rule, the Supreme Court of the Russian Federation summarises the judicial practice of the invalidation of transactions concluded in circumvention of the counter-sanctions. You can study in more detail the positions of the Russian Supreme Court, as well as the judicial practice that was not included in the Thematic Review, by clicking on this link. If you would like more information on the procedural aspects of the counter-sanctions covered in the Thematic Review, please study our newsletter by clicking on the following link.

5.

Letter No. 05-06-13RM/56768 of the Ministry of Finance of Russia dated 1 July 2026 "Official Clarifications No. 5 on the Issues arising from the Application of Decree No. 618 dated 8 November 2022"

The Ministry of Finance of Russia clarified that any amendments to the charter of a limited liability company, which stipulate the establishment of, amendments to or termination of the powers of the bodies of a limited liability company, do not require a permit of the Government Commission. There was legal uncertainty on this matter prior to the issue of the indicated clarifications.

The Ministry of Finance of Russia also clarified that a permit of the Government Commission is not required to change the size of the participation interest of a participant if a retained or unsold participation interest in the charter capital of a limited liability company or a portion thereof is cancelled in accordance with Article 24 of Federal Law No. 14-FZ dated 8 February 1998 “On Limited Liability Companies” by the deadline established by this Article, or if the size of the charter capital of the company is reduced by the par value of this participation interest or a portion thereof.

6.

Decree No. 604 of the President of the Russian Federation dated 24 August 2026 "On Measures to Safeguard the Security of the Critical Infrastructure Facilities of the Russian Federation"

The Decree stipulates that the temporary administration of critical infrastructure facilities may be introduced if their owners:

•

do not take measures to safeguard their security,

•

fail to take measures promptly to safeguard their security,

•

violate requirements on safeguarding their security,

•

pose a threat to the security or the normal functioning of critical infrastructure facilities, 

•

do not restore or fail to restore promptly the functioning of these facilities. 

The security requirements that the owners of critical infrastructure facilities are required to adopt are established by the regulatory and legal acts of the Russian Federation and by the decisions of bodies responsible for the security of critical infrastructure facilities.

Temporary administration is introduced and ceases on the basis of a decision of the Russian Government adopted on the orders of the President of the Russian Federation.

The above procedure for introducing temporary administration applies to a wide range of organisations and individuals. It also applies to persons connected to unfriendly states. Furthermore, unlike the temporary procedure introduced by Decree No. 302 of the President of the Russian Federation dated 25 April 2023 "On the Temporary Administration of Certain Property", which applies solely to persons from unfriendly states, the temporary procedure under Decree No. 604 dated 25 April 2026 is not introduced on the basis of a Presidential Decree, but instead on the basis of a decision of the Government (on the orders of the President of the Russian Federation). What is important here is not only the formal distinction, but also the appearance of a separate legal basis, with established criteria for introducing temporary administration against persons from unfriendly states (Decree No. 302 of the President of the Russian Federation dated 25 April 2023 has been criticised for the opacity of the legal grounds for introducing external administration).

7.

Decree No. 750 of the President of the Russian Federation dated 15 October 2025 "On the Introduction of an Amendment to Decree No. 1285 of the President of the Russian Federation dated 11 September 2012 "On Measures to Protect the Interests of the Russian Federation during the Exercise of Foreign Economic Activity by Russian Legal Entities"

Decree No. 1285 of the President of the Russian Federation dated 11 September 2012 "On Measures to Protect the Interests of the Russian Federation during the Exercise of Foreign Economic Activity by Russian Legal Entities" applies to instances when strategic enterprises included in the list approved by Decree No. 1009 of the President of the Russian Federation dated 4 August 2004 "On the Approval of the List of Strategic Enterprises and Strategic Joint Stock Companies, are required by the legislation of foreign states to perform certain actions.

Such strategic enterprises are only entitled with the preliminary consent of the federal executive authority duly authorised by the Government of the Russian Federation to provide information, change their pricing policies, alienate participation interests in foreign organisations, to do business abroad, dispose of real estate located abroad.