Publications

On August 4, 2026, the President of the Russian Federation signed Decree No. 550, introducing amendments to Presidential Decree No. 95 of March 5, 2022 “On the temporary procedure for fulfilling obligations to certain foreign creditors”.

The amendments soften the restrictions introduced by Decree No. 95, which in June had been extended to bank deposits by Presidential Decree No. 377 of June 1, 2026.

In particular, Decree No. 377 had extended to obligations arising from bank deposit contracts the special regime established by Decree No. 95 for the performance of obligations by Russian debtors to non-resident creditors from “unfriendly” states. Under that regime, payments exceeding 10 million rubles per month were required to be made through special type “C” escrow accounts, unless a specific authorization from the Government Commission on Foreign Investment Control was obtained.

Decree No. 550 supplements Decree No. 95 with a new paragraph 12(1), under which the special procedure for fulfilling deposit obligations does not apply to bank deposits held by individuals, as well as by branches, representative offices and other secondary offices of organizations registered in the Russian Federation.

Furthermore, Decree No. 550 allows the aforementioned individuals and legal entities to receive in rubles the funds previously credited to type “C” accounts between June 1 and August 4, 2026 (the date of entry into force of the Decree).



On August 24, 2026, the President of the Russian Federation signed Decree No. 604 “On measures to ensure the security of critical infrastructure facilities of the Russian Federation”.

The measure allows for the introduction of a temporary administration regime for facilities whose owners have not adopted (or have adopted late) adequate measures to ensure their security, or have violated safety regulations, or have created a threat to the security or normal functioning of the facility (including cases where counter-drone measures proved ineffective), or have not restored (or have restored late) the facility’s operation.

The decision on temporary administration is taken by the Government of the Russian Federation on the basis of a presidential order and normally entails the transfer of control over the infrastructure to the Federal Agency for State Property Management (Rosimushchestvo).

The measures may concern not only a single infrastructure facility, but also the entirety or part of a Russian company’s assets, its shareholdings in Russian legal entities, and property rights.

It is noted that the temporary administration regime does not transfer ownership of the infrastructure to the State, but only its management, since the administrator is not authorized to dispose of the assets under administration and the related expenses are financed from the proceeds derived from their management.

The list of facilities referred to in the Decree is open (it includes facilities in the energy, petrochemical, industrial, communications, transport, logistics sectors, critically important and potentially dangerous facilities, as well as other facilities of particular relevance to ensuring the security and economic stability of the Russian Federation), which determines a rather wide potential scope of application.



On June 17, 2026, the Supreme Court of the Russian Federation published Review No. 8/2026, providing binding guidance for commercial courts on the application of special economic measures (Russian counter-sanctions).

The document, approved by the Presidium of the Court, provides a strict and substantive interpretation of the law: courts are called upon to look beyond the formal structure of transactions, declaring void all artificial schemes aimed at circumventing prohibitions – from splitting payments to evade currency limits, to assignment of claims to third parties, to real estate purchases in favor of counterparties from “unfriendly” states.

The Review also reaffirms the prohibition on applying foreign laws or recognizing foreign judgments contrary to Russian public policy, with a strengthening of the exclusive jurisdiction of Russian courts, which are authorized to issue injunctions preventing parties from resorting to foreign forums.

With regard to intellectual property rights holders from “unfriendly” states, the Review provides that the special payment regime via type “O” accounts may be derogated only on condition that they demonstrate that they are effectively operating in Russia and regularly fulfilling their contractual obligations, thus establishing a narrow exception subject to strict evidentiary conditions.

The Review further clarifies that, with regard to financial intermediaries, international (foreign) sanctions may constitute force majeure only in the presence of objectively insurmountable obstacles external to the operator’s sphere of control (such as, for example, the blocking of a transfer by a foreign correspondent bank), and provided that the intermediary demonstrates that it could not reasonably have foreseen or avoided the impediment. Conversely, Russian countermeasures (such as payment prohibitions towards entities from “unfriendly” states) do not constitute force majeure for Russian operators, being domestic rules which they are required to know and comply with.



On August 4, 2026, the main amendments to the Law “On Foreign Investments” formally entered into force, granting Russian business owners and government authorities the right to apply to court to terminate buyback call options granted to foreign investors who had disposed of Russian assets after February 22, 2022. The mechanism applies to investors from “unfriendly” states, as well as persons and Russian companies controlled by them.

Grounds for filing a claim include support for “unfriendly” actions, financing of terrorist or extremist activities, termination of operations in Russia, and improper performance of contractual obligations.

Other grounds for termination include a deviation of the buyback price from the market value by more than 25%, or evidence that the Russian purchaser had to make additional investments without which the business would have been suspended or significantly reduced.

Claims may be filed with the Arbitration Court of the Moscow Region.



At its meeting on July 24, 2026, the Bank of Russia continued its monetary easing cycle, reducing the key rate by 25 basis points to 14% per annum. This decision marked the tenth consecutive cut and was taken despite most analysts’ expectations of a hold at 14.25%. The regulator noted moderate economic growth in the second quarter of 2026, placing the estimated core inflation rate in a range between 4% and 5%. The next meeting is scheduled for September 11, 2026.



The Law “On Digital Currencies and Digital Rights”, promulgated on August 4, 2026, establishes a legal framework for the legitimate circulation of cryptocurrencies in Russia.

In particular, the Law expressly authorizes the use of cryptocurrencies in foreign trade contracts concluded with non-residents for the payment of goods, works and services (while the prohibition on similar use for domestic payments remains in force).

The Law introduces a clearly defined category of authorized market operators: the circulation of digital currencies will be permitted exclusively through specialized intermediaries, while accounting and custody will be entrusted to digital depositaries.

The Law enters into force on September 1, 2026, while the obligation to operate through authorized intermediaries takes effect from July 1, 2027.



The President of the Russian Federation has signed a measure amending Federal Law No. 115-FZ of July 25, 2002 “On the legal status of foreign citizens in the Russian Federation”, which allows authorities to revoke work patents or work permits from foreign nationals who do not have a sufficient level of income.

Under the new rules, in the absence of minimum income requirements, patents will be cancelled and the foreign national (together with their minor children) will be required to leave Russia within 15 days, unless they hold other valid grounds for stay.

With regard to work permits issued to highly qualified specialists (HQS), as from March 1, 2027, the minimum salary will increase – in most cases – almost threefold compared to the current level of 250,000 rubles per month and will amount to:

• 358,500 rubles per month – for teachers, medical workers, research workers, residents of special economic zones and other categories of foreign nationals referred to in Paragraph 1 of Article 13.2 of Federal Law No. 115-FZ of July 25, 2002;
• 717,000 rubles per month – for other categories of HQS.

On July 26, 2026, Federal Law No. 265-FZ of July 26, 2026 entered into force, amending the procedure for compiling the list of countries ensuring adequate personal data protection. Previously, the list included member states of the Council of Europe Convention No. 108, whereas now the determining factor will be the compliance of a country’s legal framework and the measures actually taken with the provisions of the Convention, as assessed by Roskomnadzor.

It should be recalled that for countries not included in the list, a stricter cross-border transfer procedure applies, allowing data transfer only after Roskomnadzor has completed its review of the relevant notification, or after the expiration of the term provided for such review.

The current list (dating from 2022 and comprising 89 countries) will also be revised: Roskomnadzor has already published a draft of the updated list, from which Ukraine has been excluded.

The list has not yet been finally approved, and it cannot be ruled out that “unfriendly” countries such as the United Kingdom, Switzerland and European Union member states may also be subsequently removed from the list.