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Russia imposes further counter-sanctions

1 March 2022

On March 1st the RF decided to implement further counter-sanctions in response to sanctions imposed by several Western countries on Russia. On this day, RF President Vladimir Putin enacted decree No. 81 “On Additional Temporary Economic Measures to Ensure Financial Stability in the Russian Federation”.

The counter sanctions in this decree include a number of measures. One measure involves the requirement of Government Commission (GC) approval for equity, real estate and certain other transactions. According to the new decree, from March 2nd 2022, several transactions between RF residents and persons associated with foreign states that have imposed sanctions against Russia (Sanctioned Persons), as well as other transactions with foreign currency, will be subject to prior approval by the GC. Sanctioned Persons (as aforementioned) include persons who are registered or have their citizenship in the foreign countries which have imposed sanctions on Russia, conduct their primary business activities in, or generate their profit primarily from activities in such countries/states as well as persons under their control. 

Under this measure, the transactions subject to prior approval of the GC include: 1. All transactions relating to the transfer of title to real estate and securities involving Sanctioned Persons 2. Extension of ruble denominated loans to such persons. 3. Transactions relating to transfer of title in real estate and securities between RF residents and non-Sanctioned Persons, where such real estate and securities were acquired by a non-Sanctioned Person from a Sanctioned Person after February 22nd 2022 4. Transactions involving certain cross-border currency operations (as specified in decree No. 79). It should be noted, that the RF Government is due to adopt the relevant procedure for issuing approvals by the GC by March 6th 2022. 

Another measure involves securities transactions consummated through a stock exchange. The new decree provides that the securities transactions (detailed in point 1 above) fulfilled through a stock exchange, may be preformed on the basis of the Russian Central Bank’s permits. These permits will need to be approved by the Russian Ministry of Finance and are expressed to include conditions for fulfillment of such transactions.

An additional new measure involves the ban on export of cash and money market instruments in excess of 10,000 US$. This new measure (effective March 2nd 2022), prohibits the export of foreign currency in cash and/or foreign currency money market instruments in an amount exceeding 10,000 US$ or it’s equivalent at the CBR official exchange rate on the export day.

More information on the counter-sanctions imposed within decree No. 81 can be found here (in Russian).