New procedure of LLC shares deals with “unfriendly” non-residents

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A special body that previously controlled deals with securities in Russian companies with residents of “unfriendly” countries now also will control participation of such non-residents in LLC shares deals – Government Commission for the Control of Foreign Investments (hereinafter referred to as the Commission).

To proceed with deal with shares of an LLC – it must be approved by the Commission.

Consent must be obtained, both in the case of deals between non-residents from “unfriendly” countries, and in case residents of the Russian Federation and residents of friendly jurisdictions.

There are also exceptions – fuel and energy companies, non-credit financial organizations and banks. In their respect, a ban on the exit of a foreign investor from an “unfriendly” country was stated by presidential decree of August 5, 2022.