Special procedure for transactions with stocks and shares of certain Russian companies

On March 29, 2024, the Russian anti-sanctions legislation was supplemented by a new Presidential Decree No. 221 “On the special procedure for the execution of certain transactions (operations) with stocks (shares in authorized capitals) of certain companies” (“Decree No. 121”). The list of companies affected by Decree No. 121 is not disclosed, and the information under paragraphs 1 and 2, which establish a special procedure for certain types of transactions with shares in certain business entities, is for official use only.

The companies directly subject to the regulation of Decree No. 121, as well as companies controlled by them, are exempt from mandatory disclosure/provision of information based on the requirements of the Russian legislation. Russian legal entities that have acquired stocks/shares in these companies are also not required to disclose or provide information. They are only required to send relevant notification to federal executive authorities and other persons authorized to receive such information and provide such information upon request of the competent authorities.