The President of the Russian Federation instructed the Government to consider the opportunity of granting clearance for the sale of Russian legal entities controlled by “unfriendly” entities only with the consent of senior officials of the Russian regions where such entities are located. The Government should issue a report on this matter by June 15, 2023.

This new condition may substantially complicate and lengthen the process of transaction clearance by the Subcommittee of the Government Commission. Although this order is not yet a normative act, we believe that many ministries may proactively accept it as a guideline to follow, without waiting for a formal procedure to be developed. This may affect transactions that are already under consideration.

We will monitor the changes and keep you updated on any developments.

We hope that the information provided herein will be useful for you. If any of your colleagues would also like to receive our newsletters, please send them this link to the electronic subscription form. If you would like to learn more about our Competition and Antitrust practice, please let us know in a return letter. We will be glad to provide you with our materials.

Note: Please be aware that all information provided in this letter was taken from open sources. Neither ALRUD Law Firm, nor the author of this letter bear any liability for consequences of any decisions made in reliance upon this information.

If you have any questions, please contact the ALRUD Partners:

Vassily Rudomino

Senior Partner
Competition/Antitrust,
Foreign Direct Investments
E: [email protected]

German Zakharov

Partner

Crisis Management, Economic Sanctions
and Compliance Practice,
Competition/Antitrust,
Foreign Direct Investments
E: [email protected]