Law Messenger

Rules for foreign investment in the Russian economy simplified

07.07.2025

On 1 July 2025 the President of Russia signed Edict No. 436 "On Additional Guarantees of the Rights of Foreign Investors" (the "Edict").

The Edict simplifies foreign investment in the Russian economy by allowing foreign investors – including investors from unfriendly jurisdictions – to purchase Russian securities without prior approval from regulators[1].

In accordance with the Edict, all foreign investor transactions must take place through "In" type bank accounts, which are to be used both to credit funds intended for investments in the Russian Federation and to receive investment proceeds (cash and other currency assets).

The use of other accounts for these purposes, such as ordinary current accounts, is not permitted. The Edict also prohibits the withdrawal of cash from "In" type accounts.

Funds from "In" type accounts may be used for the following operations:

The acquisition of equity securities at their initial placement (IPO) or on the organized market on the basis of a public offering
The alienation of such securities on the public market
The receipt of income (dividends, coupons) on such securities
Placement in deposits with Russian banks and the fulfillment of obligations to repay deposits
The conclusion of derivative transactions on the public market and the fulfillment of related obligations

Securities acquired by foreign investors in the manner prescribed by the Edict must be credited to "In" type securities accounts (the legal regime for those accounts is to be established in due course by the Central Bank of the Russian Federation).

The Edict expressly provides that the legal framework which it establishes falls outside most of the restrictions imposed on unfriendly persons.

Thus, the Edict formally allows investors from unfriendly jurisdictions to enter into transactions involving Russian assets and to transfer proceeds abroad.

Show references

[1] In accordance with the provisions of Edict No. 81 of the President of the RF dated 1 March 2022, Edict No. 95 of the President of the RF dated 5 March 2022, Edict No. 126 of the President of the RF dated 18 March 2022, Edict No. 254 of the President of the RF dated 4 May 2022, Edict No. 520 of the President of the RF dated 5 August 2022, Edict No. 618 of the President of the RF dated 8 September 2022, Edict No. 737 of the President of the RF dated 15 October 2022