Bank of Russia Clarifies Decree No. 95 Rules for Non-Resident Bank Deposits

On 14 July 2026, the Bank of Russia published an official clarification on certain issues related to the application of the provisions of Decree No. 95 of the President of the Russian Federation dated 5 March 2022, to obligations arising from bank deposits held by “unfriendly” non-residents with Russian banks.

Legal mechanisms for terminating the rights of “unfriendly” foreign investors to buy back Russian assets

On 4 August 2026 the Russian President signed a law providing for the possibility of terminating, by judicial procedure, the right of a “unfriendly” foreign investor that has withdrawn from the Russian market to buy back Russian assets.

The Russian Ministry of Finance has clarified additional exemptions from special permit requirements set forth by Presidential Decree No. 618

On 10 July 2026, the Ministry of Finance of the Russian Federation published official clarification No. 5 on the application of Presidential Decree No. 618 of 8 September 2022. The Clarification identifies two additional exemptions from the special clearance procedure set forth by Decree No. 618.

Increased Liability for Violations of FAS Russia Merger Clearance Requirements

On 29 December 2025, Federal Law No. 562-FZ “On Amendments to Articles 3.5 and 19.8 of the Code of Administrative Offences of the Russian Federation” was adopted.

Toughening the requirement for localisation of personal data

On 28 February 2025, Law No. 23 was adopted, amending the regulation of personal data. These changes will come into force on 1 July 2025.

The amendments significantly transform the requirement for localizing personal data of Russian citizens.