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The President approved a list of instructions following the March 18, 2025, plenary meeting of the Congress of the Russian Union of Industrialists and Entrepreneurs.
The President instructed the Government of the Russian Federation to draft amendments regarding the procedure for approving deals (transactions) whereby persons from unfriendly countries acquire the title to, ownership and use of real property with a view to conducting entrepreneurial activity in the Russian territory, the right to directly or indirectly dispose of shares (equity stakes) in business entities, or other rights enabling them to operation business entities and/or terms for pursuing their business operations, including:
taking into account the circumstances of termination (reduction) and/or continuation of business activities in the Russian Federation by persons from unfriendly foreign countries after February 22, 2022;
taking into account the specific business activities of the persons from unfriendly foreign states who plan to carry out such activities in the territory of the Russian Federation;
the need for persons from unfriendly foreign countries to assume financial obligations and provide other guarantees regarding the pursuit of their business activities in good faith and in an responsible manner in the territory of the Russian Federation;
prioritising the interests of Russian business entities which started or continued business activities after February 22, 2024, in the corresponding sectors in the territory of the Russian Federation.
The above changes should form a specific framework for foreign investors in terms of enabling them to exercise their right to buy back shares (equity stakes) in the business entities they had divested after February 22, 2022, on non-market terms, while ensuring the protection of the rights and legitimate interests of Russian citizens and legal entities who own these shares (equity stakes).
In addition, the Government was instructed to approve and regularly update the list of persons from unfriendly foreign countries who, after February 22, 2022, ceased (scaled own) business activities in the territory of the Russian Federation, by providing for the inclusion in this list of information on the circumstances of the cessation (scaling down) of these activities, shareholders (participants) of such entities and their beneficial owners, as well as other information.
April 18, 2025