Publications

The European Union has adopted its 20th sanctions package, introducing additional restrictive measures across the energy, financial, trade and defense sectors, including over 120 new individual and entity listings. The package targets operators in Russia’s oil industry, including those linked to the “shadow fleet”, and expands vessel designations subject to port access and service restrictions. Additional measures address maritime activities, including due diligence requirements for tanker sales and restrictions related to liquefied natural gas infrastructure.

In the financial sector, the EU has imposed transaction bans on a number of Russian banks and certain non-EU financial institutions, alongside new restrictions related to the use of crypto-assets in transactions with a Russian nexus. The package also extends export controls and designations affecting entities involved in Russia’s military-industrial complex, including companies located in third countries.

Further measures include expanded trade restrictions and enhanced anti-circumvention tools. In particular, the EU has introduced targeted export restrictions on certain high-risk goods to Kyrgyzstan, alongside broader controls on:

• certain industrial and manufacturing equipment (such as metalworking machinery, heavy machinery including tractors, and articles of vulcanized rubber);
• scientific and technical goods (including laboratory glassware, chemical additives such as high-performance lubricants, and certain energetic materials);
• technology and communications equipment (including commercial radios and critical electronic components);

especially where there is a risk of onward supply to Russia.

The package also introduces additional import and export bans, as well as measures relating to intellectual property protection and cybersecurity services, reflecting a continued broadening of the EU sanctions framework. In particular, the EU seeks to mitigate risks of uncompensated use or expropriation of intellectual property in Russia, including through local judicial or administrative actions affecting foreign rights holders. The new measures also provide a basis for restricting business with third-country entities involved in enforcing Russian legal claims, as well as for targeting companies that benefit from the temporary management or expropriation of EU-owned assets and the use of EU intellectual property under Russian counter-sanctions regimes. In parallel, EU companies are granted clearer grounds to seek damages before EU courts in connection with losses arising from such claims.


At its meeting on April 24, 2026, the Bank of Russia reduced the key rate to 14.5%, following previous cuts to 15.0% in March 2026 and to 15.5% in February 2026.

This marks the eighth consecutive reduction since the easing cycle began in June 2025, when the key rate stood at 21%.

According to the Bank's communication, the Russian economy is gradually moving towards a more balanced growth path, while inflationary pressures remain present.

Future rate decisions will continue to depend on the inflation outlook, inflation expectations and domestic demand dynamics. The Bank of Russia Board of Directors will hold its next key rate meeting on June 19, 2026.


The Russian Government has submitted a bill to the State Duma introducing tighter requirements for labor migrants and their employers, with a particular focus on highly qualified specialists (HQS).

The bill provides for a significant increase in the minimum salary threshold for most HQS to RUB 717,000 per month, with annual indexation based on average wage growth. It also introduces a mechanism for automated verification of foreign employees’ income through tax authorities.

Under the Russian legislative process, the bill must pass three readings in the State Duma before it can be approved by the Federation Council and signed by the President. As of today, the bill has passed the first reading in the State Duma.

The majority of the amendments are expected to enter into force from January 1, 2027, while the new salary thresholds for HQS are scheduled to apply earlier, from September 1, 2026.


On March 8, 2026, the President of the Russian Federation signed amendments to Federal Law No. 57-FZ¹, significantly revising the regulation of foreign investments in strategically important companies. The changes primarily affect sectors such as subsoil use and fisheries, and will enter into force within 90 days of publication (with certain provisions effective immediately).

The amendments broaden the definition of a foreign investor, including entities controlled by a wider group of persons, and expand the list of strategic activities to cover additional mining operations and certain fisheries-related businesses. New categories of strategic entities have also been introduced, including some non-commercial organizations and companies holding strategic licenses, even if not yet operational.

The reform strengthens regulatory oversight, extending the scope of transactions requiring prior government approval and introducing additional notification and disclosure obligations, including information on beneficial owners and controlling persons. Existing foreign investors may also be required to confirm or restructure their holdings in certain sectors, particularly fisheries.

Overall, the amendments reflect a continued tightening of state control over foreign participation in key industries, alongside increased transparency requirements and expanded regulatory coverage.


The Russian Government has submitted a bill introducing mandatory navigation sealing for certain categories of goods transported by road and rail across Russia. The requirement will apply to both imported and transit cargo, with the new regime expected to enter into force from March 1, 2027.

Under the proposed bill, covered shipments will need to be equipped with electronic tracking seals compliant with Eurasian Economic Union (EAEU) standards. The specific list of goods, exemptions, and designated sealing locations will be defined in secondary legislation expected by November 2026. The rules will not apply where shipments are already tracked under the existing EAEU navigation seal framework.

In practical terms, the key difference with the already existing EAEU navigation seal framework lies in the scope and regulatory flexibility. While the EAEU framework applies to a predefined list of high-risk goods (such as tobacco and alcohol), the proposed Russian mechanism would allow authorities to extend tracking requirements to additional categories of cargo at national level, potentially increasing both administrative and financial burdens for market participants.


On April 27, 2026, Federal Law No. 104 FZ dated April 25, 2026² was signed and officially published, introducing extensive amendments to the Russian Tax Code. These changes aim to support small and medium sized enterprises (SMEs) and ease the transition to the new tax rules effective from 2026.

Under the law, SMEs may aggregate income from several qualifying preferential activities to meet the 70% threshold of core income required to apply reduced social contribution rates. Manufacturing companies are allowed to use the reduced rate without meeting this condition at all.

For small businesses that began paying VAT in 2026, as well as for entrepreneurs who lost the right to use the PSN (“patent” taxation system), a special transitional period has been established. They will be entitled to deduct input VAT on goods purchased while still under the old regime, and in certain cases may not charge VAT on advances received before 2026.


Tax authorities have launched a large scale preventive campaign to identify signs of business fragmentation designed to obtain unjustified tax benefits.

Taxpayers are currently receiving notices of violation risks or summons to commissions even in cases where newly registered sole proprietors have not yet carried out any actual business activity.

Preventive controls are conducted without on site audits — the system automatically analyses formal indicators such as interdependence between subjects (family ties, shared employment history), use of common resources and brands, and lack of autonomy of individual entities. The Federal Tax Service uses data from the “VAT ASK” system, fiscal data operators, civil registry databases, and employment contract records.


Starting from April 2026, the so called “Goods waiting confirmation system” (SPOT) has been operating in test mode, affecting all importers and carriers delivering goods by road from EAEU countries (Kazakhstan, Belarus, Armenia, Kyrgyzstan). The system is scheduled for full launch on June 1, 2026. The purpose of SPOT is to reduce “grey” imports and prevent schemes where goods are imported using inactive importers and then sold without paying taxes through companies applying simplified tax regimes.

Two calendar days before crossing the border, the importer must submit a “Document on Expected Supply” (DOPP) to the Federal Tax Service and transfer a security payment equal to the estimated VAT and excise duties. The tax authority verifies the document and issues a QR code, which is passed to the carrier. Without the QR code at the border, customs clearance will not be allowed. The system does not apply to goods from non EAEU countries, oil, electricity, goods for personal use, and certain other exceptions.

From June 1, 2026, imports without a DOPP and QR code will be prohibited. A separate DOPP must be filed for each consignment, even in case of partial delivery or defective goods. Fines for failure to submit a DOPP are planned to be introduced into the Code of Administrative Offences. The security payment is not required for large taxpayers, tax monitoring participants, authorized economic operators (AEOs), nor for transit or imports into special economic zones (SEZs).

Businesses are advised to start testing DOPP submission through EDI operators now. From May 1, submission becomes mandatory, and by June 1 it should be ensured that every shipment from the EAEU has a QR code with the carrier. It is recommended to review logistics chains, amend contracts with counterparties and carriers, and incorporate the security payment into financial planning.



Russian customs authorities have started charging businesses increased duties (15–50%) on some products originating in “unfriendly” states, even when those goods are purchased and imported from EAEU countries. Previously, a letter from the Russian Federal Customs Service exempted such goods, which had acquired the status of EAEU goods, from additional payments. A new clarification from the Russian Federal Customs Service effectively revokes that exemption.

In this respect, it should be noted that recent Russian special provisions have increased customs duties on a range of products originating from “unfriendly” states, with rates ranging from 15% to 50% (depending on the product category), until the end of 2027.

At risk of additional charges are cosmetics, clothing, perfumery, alcohol, and other everyday consumer goods imported through EAEU. For example, for French perfume the base duty is 6.5% while the increased rate is 20%; for lipstick the rate is 35% instead of 6.5%.

Such additional charges contradict the basic rules of the Union, where duty is paid once upon import for domestic consumption.

Although in a number of cases companies have successfully recovered the payments related to extra customs duties through the courts, case law is still fragmented, and legal uncertainty is growing.

Customs is likely fighting schemes to circumvent counter sanctions measures, but legitimate businesses that have consolidated goods in EAEU countries for years are also being affected. In this context of uncertainty, some companies are now reconsidering their product range or revising their import logistics.