On 27.03.2023 the Subcommission of the Government Commission for the Control of Foreign Investments published an Extract from the minutes of its meeting dated 02.03.2023. This document provides for a new requirement which has to be fulfilled in order to obtain Subcomission’s permission with regard to sale of shares of Russian companies. Foreigners from unfriendly states are now obliged to transfer funds to state budget in the amount of 5%-10% of the target’s valuation. 

In addition to the previously adopted rules the Sub-Commission of the Government Commission for the Control of Foreign Investments (hereinafter referred to as the "Sub-Commission") published new conditions for issuing licenses on transactions with shares (stocks) in Russian LLC and JSC conducted with persons of foreign unfriendly states.

The Ministry of Industry and Trade has recently published a new decree amending the Decree No. 1532 of 19 April 2022 “On goods admissible for parallel import, that shall not be restricted by art. 1359(6) and 1487 of the Civil Code”.

New alert was released jointly by OFAC, BIS and DOJ on March 02, 2023 on suspicions third parties transactions under Ukraine-Russia restrictions. Another list of criteria was introduced that should help to identify and ‘aggressively prosecute’ those who violate U.S. sanctions and export control laws.

On 22 February 2023 the Ministry of Finance published on its official website a list of appraisers that the Ministry recommends to involve in the valuation of assets to obtain permits from the Government Commission within the framework of Presidential decrees No 79 of 28 February 2022 and No 81 of 01 March 2022. The list includes 42 appraisal organizations recommended for evaluation of business (stocks, shares, units) and real estate, and only real estate.

On 17 February 2023, Federal Law No. 24-FZ of 17.02.2023 “On Amendments to Certain Legislative Acts of the Russian Federation” was published, amending the regulation of the movement of freight transport across the Russian border.

According to the new rules, starting from 1 September 2023, the crossing of the state border by cargo vehicles will be carried out through special crossing points after reserving the date and time.

Arbitrazh court for the Moscow City issued a judgement under the claim of a Russian entity to Alfa-Bank JSC. By this decision the court ordered the Russian bank to make a refund of the frozen funds allocated on the accounts of a correspondent bank to its client as well as charged the bank with penalties and interest for the use of its client’s money.

At the end of 2022 the new Law was adopted, which extended numerous counter-sanctions measures. Among other things it extends the ban on Russian insurers to conclude transactions with number persons until 31 December 2023.

On February 6, 2023, the EU official journal published news about delisting Dmitry Ovsyannikov, the former governor of Sevastopol, from the sanctions list. The exclusion was preceded by the decision of the EU court of 26 October 2022 following the review of Ovsyannikov's appeal.

On 8 February 2023 Alexey Repik, the founder of R-Pharm – Russian pharmaceutical company, producing, among other things, drugs for COVID-19 (e.g. coronavir (favipiravir) and artlegia (olokizumab)) was listed in the UK Sanctions List.

Reasoning behind this decision is that he holds the position of the Chairman of the Board of R-Pharm, which receives financing from the Russian Direct Investment Fund – a Government of Russia-affiliated entity. Moreover, Alexey Repik is also designated as a person associated with Vladimir Putin, the Russian President.