Law reviews
Starting from February 24, 2022, the Firm prepares overviews of changes in legislation and sanctions. This allows to monitor changes in currency, banking, corporate, and other regulations and respond to them in a timely manner.
22.02—15.03
  1. Residents of the Russian Federation are obliged to sell 80% of foreign currency earnings received from foreign economic activity.
  2. From March 1, 2022, the residents of the Russian Federation will not be able to carry out currency transactions related to the provision of foreign currency to non-residents under loan agreements without the permission of the Government Commission.
  3. From March 31, 2022 the transfers of non-residents from Russian credit institutions to foreign accounts were suspended.
  4. Foreign investors will not be able to receive dividends and interest on securities of Russian issuers for six months.
  5. In some cases, the property of foreign citizens and stateless persons who have committed crimes against citizens of the Russian Federation may be arrested.
15.03—22.03
  1. Additional competencies of the Central Bank of the Russian Federation in relation to currency transactions were given, the necessity to obtain the consent of the Central Bank of the Russian Federation for a number of monetary transactions was introduced.
  2. The procedure was implemented for the conclusion of transactions, which entail the emergence of ownership of real estate and rights to securities, with persons from unfriendly states, with the approval of the Government Commission.
  3. It is established that no consent of foreign creditors, their personal appearance or submission of documents is required to open C-type bank accounts in the name of foreign creditors.
  4. A ban on the export, sale or supply of dollars and euros to Russia was introduced.
  5. A number of other legislative changes have been introduced in various areas: the double check of title documents for land during commissioning has been abolished, the possibility to write off penalties under state contracts in case of breach of obligations due to sanctions has been established, credit vacations have been provided, etc.
22.03—29.03
  1. The amount of advance payments that residents may transfer to non-residents from unfriendly countries under the contracts for the provision of services, performance of works, transfer of results of intellectual activities was reduced by the Central Bank of the Russian Federation to 30%.
  2. Legal entities from unfriendly countries will not be able to buy foreign currency on the domestic currency market of the Russian Federation.
  3. Draft Federal Law is being developed, according to which currency clauses in domestic contracts will be null and void.
  4. Receipt of property and property rights, including securities, from controlled foreign companies will not be subject to personal income tax.
  5. Accredited IT-companies will pay income tax at a rate of 0% from 2022 to 2024.
29.03—12.04
  1. The Central Bank of Russia has eased restrictions on the transfer of funds abroad for individuals.
  2. Residents under the control of persons from unfriendly countries will be able to conclude transactions for the purchase of shared construction projects.
  3. The government introduced a moratorium on bankruptcy starting April 1, 2022, for six months.
  4. On May 10, 2022 a ban was introduced on rendering of a number of services by the persons of the EU member states in respect of trusts and foundations, if the founder or the beneficiary in such a trust or foundation is a citizen of the Russian Federation.
  5. The US and Germany have announced the cessation of exchange of tax information with Russia.
12.04—19.04
  1. Residents were granted the right to make ruble transfers to their foreign accounts and to convert money abroad into foreign currency.
  2. The Government Commission allowed resident individuals to carry out nonrefundable transactions for the transfer of immovable property to their close relatives from unfriendly countries.
  3. The possibility has been provided until the end of 2022 to rent state or municipal land without an auction, if it is necessary for the production of import-substituting products.
  4. Clarification by the Supreme Court that enforcement proceedings shall be suspended by a bailiff in whole or in part if the debtor is subject to a moratorium on the initiation of bankruptcy proceedings.
  5. Extended EU ban on deposits to crypto wallets, as well as on the sale of banknotes and transferable securities denominated in any official currency of EU member states, Swiss and Cypriot bans on the registration and servicing of Russian trusts were introduced.
19.04—06.05
  1. New restrictions have been introduced on transactions with persons under Russian sanctions.
  2. A new procedure was established for the payment of profits of legal entities that are residents of the Russian Federation to participants from unfriendly countries using C-type accounts.
  3. A ban was introduced for Russian banks to provide foreign authorities with information, data and documents about clients and their transactions.
  4. The government commission relaxed restrictions on real estate transactions with persons from unfriendly countries.
  5. The obligation to pay VAT on the sale of certain intellectual property and the transfer of rights to use them by contract of commercial concession was abolished.
  6. A number of other legislative changes were introduced in different areas: The Federal Tax Service extended the deadline for payment of property taxes and advance payments in a number of regions, the deadline for payment of insurance premiums for the second and third quarters of 2022 was extended by a year, the list of "parallel import" goods was approved.
  7. Great Britain has imposed a ban on the export of business services to Russian persons, Liechtenstein has prohibited the registration of trusts and the provision of services to them.
06.05—16.05
  1. Some residents engaged in foreign economic activities are allowed not to sell foreign currency earnings.
  2. The range of persons who will not be considered as persons from unfriendly states was expanded.
  3. The Russian Government’s navigator on stabilization measures in the context of sanctions was released.
  4. Cyprus approved a bill on the introduction of tax incentives for the managers and employees of foreign companies that have relocated to Cyprus.
  5. The U.S. has prohibited a number of services for the benefit of Russian buyers.
  6. A list of persons under Russian sanctions was published.
16.05—26.05
  1. The requirement for the mandatory sale of foreign exchange earnings was reduced to 50%.
  2. New thresholds for the transfer of funds abroad for individuals have been established.
  3. The Central Bank of the Russian Federation relaxed the temporary procedure for cash currency transactions.
  4. The Central Bank published an official clarification of the application of the Presidential Decrees Nos. 79, 81, 95 and 126.
  5. Cyprus has launched an online list of beneficiaries.
26.05—15.07
  1. The Government Commission has cancelled the requirement for the mandatory sale of foreign currency proceeds and allowed residents participating in foreign economic activities to credit foreign currency proceeds to foreign accounts.
  2. Payments to foreign rights holders from unfriendly countries will have to be made through O-type accounts.
  3. Russian credit and non-credit financial organizations are able to carry out transactions for the sale of foreign securities to persons from unfriendly countries under certain conditions.
  4. The amount of administrative fine for violation of the currency legislation was reduced.
  5. Residents are allowed to perform transactions related to payment for shares, contributions, and interests in the property of non-resident legal entities from friendly and unfriendly countries.
  6. Residents may purchase real estate from foreign legal entities from nonfriendly countries using a C-type account.
15.07—04.08
  1. Restrictions on crediting foreign currency to foreign accounts have been cancelled with a number of exceptions.
  2. Restrictions on the withdrawal of foreign currency in cash are extended until March 9.
  3. The Ministry of Economic Development clarified the application of the Presidential Decree № 322 of 27.05.2022 "On temporary order of obligations to certain right holders", including in terms of what right holders will be considered unfriendly, what legal relations are covered by the decree, and what are the consequences of money transfer to the account of O-type.
  4. The limitation on the amount of prepayments payable to non-residents under foreign economic transactions has been cancelled.
  5. The Federal Tax Service has approved the list of states with which there is an automatic exchange of financial information.
05.08—21.11
  1. A temporary ban was introduced on foreign persons from unfriendly countries to carry out transactions with the shares of a number of Russian companies.
  2. A ban on the provision of wallet, account or depository services for cryptoassets to Russian individuals and residents was included in the Eighth Package of EU sanctions.
  3. A new procedure for fulfillment of liabilities under bank account (deposit) agreements denominated in foreign currency and Eurobonds was introduced.
  4. Transactions with UAE real estate worth more than 15,000 (approx.) US dollars will have to be registered.
  5. The British Overseas Territories and possessions of the British Crown are added to the "unfriendly" states.
21.11—07.12
  1. A draft law is being considered to levy a 13% personal income tax on relocated employees working remotely.
  2. The Council of the EU approved the inclusion of circumvention of EU sanctions in the list of crimes.
  3. Access to the registers of beneficial owners of companies in some European countries, in particular Cyprus, is restricted.
2022
08.12.22—16.02.23
  1. The ninth package of EU sanctions against Russia has been adopted, under which, among others, the Moscow Credit Bank, the Far Eastern Bank and the All-Russian Bank for Development of Regions are subject to restrictions.
  2. The United States has included Rosbank in the SDN List. The OFAC license to curtail operations with Rosbank is valid until 15 March 2023.
  3. The Government of the Russian Federation has responded to the price cap on oil and petroleum products.
  4. On February 6, 2023, a special procedure for settlements between certain exporters and their suppliers is in effect.
  5. The Bank of Russia has determined the rules for the formation of special mutual funds with blocked assets.
17.02—22.03
  1. The tenth package of EU sanctions against Russia has been negotiated.
  2. The president of Russia advocates easing restrictions on the withdrawal of dividends from unfriendly countries. The Russian Government is developing the criteria and procedure for the withdrawal of these funds.
  3. The Russian Central Bank has extended restrictions on the withdrawal of cash currency for citizens and companies.
  4. Russian banks, which carry out currency transfers, are increasing the requirements for them or curtailing such operations altogether.
  5. The Central Bank proposes a way to compensate for the blocked assets of Russians at the expense of profits from the frozen funds of non-residents in Russia.
  6. The presidential decree clarified the procedure for transactions with securities of Russian issuers, acquired from non-residents from unfriendly countries after March 1, 2022.
2023
22.03—31.03
  1. The European Union plans to monitor sanctions circumvention schemes.
  2. The Government Commission introduces temporary easing of loans by Russian individuals in foreign currencies.
  3. The Central Bank of Russia extends restrictions on foreign transfers and on the sale of securities of unfriendly countries to unqualified investors.
  4. According to the decision of the Central Bank of Russia SWIFT will be disconnected for domestic transfers in Russia on 1 October.
  5. MTS Bank winds down its operations in the UAE.
03.04—21.04
  1. Norway has joined the EU's restrictive measures. Banks in Armenia and the UAE are blocking accounts of Russian individuals, following sanctions.
  2. The Bank of Russia plans to restrict investment of mutual funds' assets.
  3. Contributions by banks to the mandatory reserve fund will vary depending on the jurisdiction.
  4. The introduction of a tax for foreign companies leaving the Russian market is being discussed.
  5. Kazakhstan will be more cautious when goods from EAEU countries cross the border. Negotiations are underway to establish a free trade zone between the EAEU and Indonesia.
  6. A new free zone will appear in the UAE, and Saudi Arabia has announced the establishment of four economic zones.
2022
22.02—15.03
  1. Residents of the Russian Federation are obliged to sell 80% of foreign currency earnings received from foreign economic activity.
  2. From March 1, 2022, the residents of the Russian Federation will not be able to carry out currency transactions related to the provision of foreign currency to non-residents under loan agreements without the permission of the Government Commission.
  3. From March 31, 2022 the transfers of non-residents from Russian credit institutions to foreign accounts were suspended.
  4. Foreign investors will not be able to receive dividends and interest on securities of Russian issuers for six months.
  5. In some cases, the property of foreign citizens and stateless persons who have committed crimes against citizens of the Russian Federation may be arrested.
15.03—22.03
  1. Additional competencies of the Central Bank of the Russian Federation in relation to currency transactions were given, the necessity to obtain the consent of the Central Bank of the Russian Federation for a number of monetary transactions was introduced.
  2. The procedure was implemented for the conclusion of transactions, which entail the emergence of ownership of real estate and rights to securities, with persons from unfriendly states, with the approval of the Government Commission.
  3. It is established that no consent of foreign creditors, their personal appearance or submission of documents is required to open C-type bank accounts in the name of foreign creditors.
  4. A ban on the export, sale or supply of dollars and euros to Russia was introduced.
  5. A number of other legislative changes have been introduced in various areas: the double check of title documents for land during commissioning has been abolished, the possibility to write off penalties under state contracts in case of breach of obligations due to sanctions has been established, credit vacations have been provided, etc.
22.03—29.03
  1. The amount of advance payments that residents may transfer to non-residents from unfriendly countries under the contracts for the provision of services, performance of works, transfer of results of intellectual activities was reduced by the Central Bank of the Russian Federation to 30%.
  2. Legal entities from unfriendly countries will not be able to buy foreign currency on the domestic currency market of the Russian Federation.
  3. Draft Federal Law is being developed, according to which currency clauses in domestic contracts will be null and void.
  4. Receipt of property and property rights, including securities, from controlled foreign companies will not be subject to personal income tax.
  5. Accredited IT-companies will pay income tax at a rate of 0% from 2022 to 2024.
29.03—12.04
  1. The Central Bank of Russia has eased restrictions on the transfer of funds abroad for individuals.
  2. Residents under the control of persons from unfriendly countries will be able to conclude transactions for the purchase of shared construction projects.
  3. The government introduced a moratorium on bankruptcy starting April 1, 2022, for six months.
  4. On May 10, 2022 a ban was introduced on rendering of a number of services by the persons of the EU member states in respect of trusts and foundations, if the founder or the beneficiary in such a trust or foundation is a citizen of the Russian Federation.
  5. The US and Germany have announced the cessation of exchange of tax information with Russia.
12.04—19.04
  1. Residents were granted the right to make ruble transfers to their foreign accounts and to convert money abroad into foreign currency.
  2. The Government Commission allowed resident individuals to carry out nonrefundable transactions for the transfer of immovable property to their close relatives from unfriendly countries.
  3. The possibility has been provided until the end of 2022 to rent state or municipal land without an auction, if it is necessary for the production of import-substituting products.
  4. Clarification by the Supreme Court that enforcement proceedings shall be suspended by a bailiff in whole or in part if the debtor is subject to a moratorium on the initiation of bankruptcy proceedings.
  5. Extended EU ban on deposits to crypto wallets, as well as on the sale of banknotes and transferable securities denominated in any official currency of EU member states, Swiss and Cypriot bans on the registration and servicing of Russian trusts were introduced.
19.04—06.05
  1. New restrictions have been introduced on transactions with persons under Russian sanctions.
  2. A new procedure was established for the payment of profits of legal entities that are residents of the Russian Federation to participants from unfriendly countries using C-type accounts.
  3. A ban was introduced for Russian banks to provide foreign authorities with information, data and documents about clients and their transactions.
  4. The government commission relaxed restrictions on real estate transactions with persons from unfriendly countries.
  5. The obligation to pay VAT on the sale of certain intellectual property and the transfer of rights to use them by contract of commercial concession was abolished.
  6. A number of other legislative changes were introduced in different areas: The Federal Tax Service extended the deadline for payment of property taxes and advance payments in a number of regions, the deadline for payment of insurance premiums for the second and third quarters of 2022 was extended by a year, the list of "parallel import" goods was approved.
  7. Great Britain has imposed a ban on the export of business services to Russian persons, Liechtenstein has prohibited the registration of trusts and the provision of services to them.
06.05—16.05
  1. Some residents engaged in foreign economic activities are allowed not to sell foreign currency earnings.
  2. The range of persons who will not be considered as persons from unfriendly states was expanded.
  3. The Russian Government’s navigator on stabilization measures in the context of sanctions was released.
  4. Cyprus approved a bill on the introduction of tax incentives for the managers and employees of foreign companies that have relocated to Cyprus.
  5. The U.S. has prohibited a number of services for the benefit of Russian buyers.
  6. A list of persons under Russian sanctions was published.
16.05—26.05
  1. The requirement for the mandatory sale of foreign exchange earnings was reduced to 50%.
  2. New thresholds for the transfer of funds abroad for individuals have been established.
  3. The Central Bank of the Russian Federation relaxed the temporary procedure for cash currency transactions.
  4. The Central Bank published an official clarification of the application of the Presidential Decrees Nos. 79, 81, 95 and 126.
  5. Cyprus has launched an online list of beneficiaries.
26.05—15.07
  1. The Government Commission has cancelled the requirement for the mandatory sale of foreign currency proceeds and allowed residents participating in foreign economic activities to credit foreign currency proceeds to foreign accounts.
  2. Payments to foreign rights holders from unfriendly countries will have to be made through O-type accounts.
  3. Russian credit and non-credit financial organizations are able to carry out transactions for the sale of foreign securities to persons from unfriendly countries under certain conditions.
  4. The amount of administrative fine for violation of the currency legislation was reduced.
  5. Residents are allowed to perform transactions related to payment for shares, contributions, and interests in the property of non-resident legal entities from friendly and unfriendly countries.
  6. Residents may purchase real estate from foreign legal entities from nonfriendly countries using a C-type account.
15.07—04.08
  1. Restrictions on crediting foreign currency to foreign accounts have been cancelled with a number of exceptions.
  2. Restrictions on the withdrawal of foreign currency in cash are extended until March 9.
  3. The Ministry of Economic Development clarified the application of the Presidential Decree № 322 of 27.05.2022 "On temporary order of obligations to certain right holders", including in terms of what right holders will be considered unfriendly, what legal relations are covered by the decree, and what are the consequences of money transfer to the account of O-type.
  4. The limitation on the amount of prepayments payable to non-residents under foreign economic transactions has been cancelled.
  5. The Federal Tax Service has approved the list of states with which there is an automatic exchange of financial information.
05.08—21.11
  1. A temporary ban was introduced on foreign persons from unfriendly countries to carry out transactions with the shares of a number of Russian companies.
  2. A ban on the provision of wallet, account or depository services for cryptoassets to Russian individuals and residents was included in the Eighth Package of EU sanctions.
  3. A new procedure for fulfillment of liabilities under bank account (deposit) agreements denominated in foreign currency and Eurobonds was introduced.
  4. Transactions with UAE real estate worth more than 15,000 (approx.) US dollars will have to be registered.
  5. The British Overseas Territories and possessions of the British Crown are added to the "unfriendly" states.
21.11—07.12
  1. A draft law is being considered to levy a 13% personal income tax on relocated employees working remotely.
  2. The Council of the EU approved the inclusion of circumvention of EU sanctions in the list of crimes.
  3. Access to the registers of beneficial owners of companies in some European countries, in particular Cyprus, is restricted.
2023
08.12.22—16.02.23
  1. The ninth package of EU sanctions against Russia has been adopted, under which, among others, the Moscow Credit Bank, the Far Eastern Bank and the All-Russian Bank for Development of Regions are subject to restrictions.
  2. The United States has included Rosbank in the SDN List. The OFAC license to curtail operations with Rosbank is valid until 15 March 2023.
  3. The Government of the Russian Federation has responded to the price cap on oil and petroleum products.
  4. On February 6, 2023, a special procedure for settlements between certain exporters and their suppliers is in effect.
  5. The Bank of Russia has determined the rules for the formation of special mutual funds with blocked assets.
17.02—22.03
  1. The tenth package of EU sanctions against Russia has been negotiated.
  2. The president of Russia advocates easing restrictions on the withdrawal of dividends from unfriendly countries. The Russian Government is developing the criteria and procedure for the withdrawal of these funds.
  3. The Russian Central Bank has extended restrictions on the withdrawal of cash currency for citizens and companies.
  4. Russian banks, which carry out currency transfers, are increasing the requirements for them or curtailing such operations altogether.
  5. The Central Bank proposes a way to compensate for the blocked assets of Russians at the expense of profits from the frozen funds of non-residents in Russia.
  6. The presidential decree clarified the procedure for transactions with securities of Russian issuers, acquired from non-residents from unfriendly countries after March 1, 2022.
22.03—31.03
  1. The European Union plans to monitor sanctions circumvention schemes.
  2. The Government Commission introduces temporary easing of loans by Russian individuals in foreign currencies.
  3. The Central Bank of Russia extends restrictions on foreign transfers and on the sale of securities of unfriendly countries to unqualified investors.
  4. According to the decision of the Central Bank of Russia SWIFT will be disconnected for domestic transfers in Russia on 1 October.
  5. MTS Bank winds down its operations in the UAE.
03.04—21.04
  1. Norway has joined the EU's restrictive measures. Banks in Armenia and the UAE are blocking accounts of Russian individuals, following sanctions.
  2. The Bank of Russia plans to restrict investment of mutual funds' assets.
  3. Contributions by banks to the mandatory reserve fund will vary depending on the jurisdiction.
  4. The introduction of a tax for foreign companies leaving the Russian market is being discussed.
  5. Kazakhstan will be more cautious when goods from EAEU countries cross the border. Negotiations are underway to establish a free trade zone between the EAEU and Indonesia.
  6. A new free zone will appear in the UAE, and Saudi Arabia has announced the establishment of four economic zones.
Official website of "Rusligal" Law Office, Moscow (Moscow Bar Association, registry number 77/2−469)
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