Long-awaited update: our renewed guide to restrictions on operations with assets for Russian residents released

The guide was supplemented by the following sections:

·???????? Access to “frozen” securities of Russian companies held by Russian individuals on their foreign accounts.

·???????? Acquisition of exclusive rights.

·???????? Purchase, rental, and leasing of aircraft.

Additionally, the recent developments were reflected in the new edition of the guide, in particular the one stated below:

·???????? The prohibition on payment by Russian residents of shares, contributions, or units in assets of a non-resident legal entity without special authorisation by the Central Bank was extended until December 31, 2025, as envisaged by the Presidential Decree № 978 of November 14, 2024.

·???????? Nonetheless, the Bank of Russia’s working group Decision № ПРГ-12-3/534 of March 6, 2024 is still in force, whereby the aforementioned transactions (operations) may be committed without prior authorisation, provided that the following two conditions are met simultaneously:

1.??? Operation is carried out in roubles or in foreign currency and its amount does not exceed the equivalent of RUB 15 million at the official exchange rate of the Central Bank as at the date of the payment, the recipient’s location being irrelevant.

2.??? The total volume of operations performed in favour of any one non-resident legal entity from April 1, 2024 does not exceed the above 15 million threshold.

Should you need an advice on currency or counter-sanctions regulations, FTL Advisers is here to help. Feel free to contact us via e-mail: [email protected].

For using the guide, please visit our Telegram channel: https://t.me/ftladvisers/2702.