The Russian President instructs to develop a procedure for the return of foreign companies to Russia

On April 18, 2025, a List of Presidential Instructions was published, which includes an instruction to develop a special procedure for the return of foreign companies[1] to Russia, and an instruction to maintain a list of foreign companies that have curtailed or discontinued operations in Russia after February 22, 2022[2].

It is anticipated that a special procedure will be established for the following transactions (operations) involving persons from so-called “unfriendly countries”:

1. Acquisition of real estate by persons from “unfriendly countries” for the purpose of owning, possessing, or using such real estate to conduct business activities in Russia;
2. Acquisition by persons from “unfriendly countries” of the rights to directly or indirectly dispose of shares (interests) in companies, or other rights that would enable them to determine the conditions of management of such companies and/or the conditions of their business activities.

What will happen to the previously granted buyback options?

Among other things, the Russian President has instructed to develop a special procedure for the sale of buyback options for Russian assets sold on non-market terms after February 22, 2022. The Russian government appears to be sending a message that the return of such assets will be scrutinized more closely by the Russian regulatory agencies and will probably require separate additional approval and compliance with some requirements that have yet to be developed.

However, it is a well-known fact that there is already a formal procedure for approving transactions (operations) involving real estate, shares (interests) in Russian companies with the participation of foreign “unfriendly” persons. Therefore, it is likely to be about the development of certain conditions for foreign companies to enter the Russian market.

We will be monitoring the situation closely and keep you informed as soon as there are any changes to the legislation.

Still have questions or want to discuss something? Send an email to Julia Talagaeva or Artem Eretenko.

 

[1] The term “foreign companies” means companies from so-called “unfriendly countries”, a list of which was approved by Directive No. 430-р of the Russian Government dated March 5, 2022

[2] http://www.kremlin.ru/acts/assignments/orders/76722 (in Russian)