On February 1, 2024, special economic measures in respect of blocked foreign persons come into force

On February 1, 2024, amendments[1] to the Federal Law No. 281-FZ “On Special Economic Measures and Coercive Measures” of December 30, 2006 will come into force, dedicated to restrictive measures in respect of so-called blocked persons.

Such measures include, in particular:
  • prohibition (restriction) of financial transactions of blocked persons;
  • freezing (blocking) of monetary funds and property of blocked persons, as well as financial transactions in the interests and in favour of such persons.

The additions also introduce the concept of a blocked person. Blocked persons are foreign states, organizations, citizens, as well as stateless persons determined by the decision of the President of the Russian Federation, as well as legal entities controlled by foreign organizations, citizens and stateless persons according to the control criteria established by this law.

The amendments establish a closed list of transactions permitted to blocked persons. These include: receipt of salary and its expenditure in the amount not exceeding 10 thousand rubles (its equivalent in foreign currency) per calendar month per each member of his family who does not have independent income, payment for medical services in the Russian Federation for himself and close family members in the amount not exceeding 10 thousand rubles (its equivalent in foreign currency) per calendar month per each member of his family, and so on. There are no restrictions on receiving and spending pensions, scholarships, allowances, social payments guaranteed by the state in accordance with the legislation of the Russian Federation. It is also allowed to pay taxes and fees in accordance with the Russian legislation. Additional restrictions may be established by sectoral laws.

The obligation to implement special economic measures in respect of blocked persons is imposed on banks, insurance organizations, microfinance organizations, leasing companies, pawnshops, payment acceptance operators, postal service organizations and other organizations from the list established by additions to the law. The law also imposes on them the obligation to report to higher supervisory authorities[2]:
  • to the Central Bank of Russia – for supervised financial sector organizations;
  • to the Federal Assay Chamber – for organizations involved in the circulation of precious metals, precious stones, jewellery and scrap thereof;
  • to the Federal Service for Supervision in the Sphere of Communications, Information Technologies and Mass Communications – for independent organizations and telecommunications operators;
  • to the Federal Tax Service – for organizers of gambling games and lottery operators with regard to activities involving the payment, transfer or provision of winnings under a contract on participation in a lottery.

Failure to comply with special economic measures in respect of blocked persons is punishable up to the deprivation of a license, prohibition of operations and cessation of activities – the relevant amendments have been made to the relevant specialized laws.

[1] Federal Law No. 422-FZ from 04.08.2023.
[2] Resolution of the Government of the Russian Federation of 22.01.2024 No. 41.