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Russian emergency legislation imposing restrictions on certain transactions involving foreigners has been recently extended

6 December 2022

The validity of the restrictions imposed by Executive Order of the Russian President No. 126 dated March 18, 2022 “On additional temporary economic measures aiming to ensure Russia’s financial stability”[1] (“Executive Order #126”) was extended for one more year until December 31, 2023, following the newly-enacted Executive Order of the Russian President No. 845 dated November 23, 2022[2] that updates §2 of the Executive Order #126.

The Executive Order #126 forbids Russian entities and physical persons (Russian residents) to execute certain equity and joint venture transactions with foreign (non-Russian resident) legal entities registered in ‘Hostile States’ without prior permission of Central Bank of Russia. Additional restrictions are imposed on non-resident holders of bank accounts in Russian banks, who are restricted in transfer of their funds abroad, and are required to accept Russian currency, rather than original currency due to them, as repayment of debts owed to them by Russian banking institutions.

Another key Executive Order, namely, the Executive Order of the Russian President No. 100 dated March 8, 2022 “On special economic measures aimed to provide Russia’s security within foreign economic activity”[3] validity was, as of October 26, 2022[4], extended up until December 31, 2022 (“Executive Order #100”). The Executive Order #100 provides the restriction of export from and import in Russia of certain goods according to lists, approved and updated by the Government of Russia.


[1] http://publication.pravo.gov.ru/Document/View/0001202203180017

[2] http://publication.pravo.gov.ru/Document/View/0001202211230042

[3] http://publication.pravo.gov.ru/Document/View/0001202203080005

[4] http://publication.pravo.gov.ru/Document/View/0001202210260004