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
AUTHORS
Vasily Makovkin
B1 Partner
Legal Services, Tax, Law and Business Support
Contact
.jpg)
Evgeniya Zhiteleva
B1 Senior
Legal Services, Tax, Law and Business Support
Contact
OTHER PUBLICATIONS
View all.jpg)
Overview of the application by Russian arbitration courts of counter-sanctions laws with respect to transactions with ‘unfriendly’ non-residents and parties under their control
On 17 June, the Presidium of the Supreme Court of the Russian Federation approved the thematic review “On Application by Arbitration Courts of Legislation on Special Economic Measures to Protect Russia’s National Interests.” It’s the first comprehensive document that courts will be required to consider in disputes concerning the application of counter-sanctions legislation.
01.07.2026
.jpg)
Overview of regulatory amendments for transactions involving strategically important companies
Federal Law No. 51-FZ dated 8 March 2026 introduced amendments to Federal Law No. 57-FZ “On the Procedure for Foreign Investment in Companies of Strategic Importance for National Defense and State Security” (Law No. 57-FZ), most of which will take effect on 7 June 2026.
02.06.2026
Risk-free reorganization: refining the mechanism for protecting creditors’ rights
A draft law to amend Article 60 of the Civil Code of the Russian Federation (the “Draft Law”) published in May 2026 modifies the mechanism for protecting creditors in corporate reorganizations. The Draft Law is based on the legal position of the Constitutional Court of the Russian Federation set forth in Ruling No. 17-P of 24 March 2026.
25.05.2026
New sector-specific rules adopted for categorizing critical information infrastructure in financial services
On 6 February 2026, the Russian Government adopted Decree No. 92, establishing sector-specific rules for categorizing critical information infrastructure (CII) in the banking sector and other segments of the financial market. The new regulation, which entered into force on 15 February 2026, requires CII entities to take immediate compliance actions.
11.02.2026
.png)
Extended producer responsibility (EPR): what has changed since 1 January 2026 and how it affects businesses
Federal Law No. 495-FZ of 28 December 2025 “On Amendments to Article 29¹ of the Federal Law ‘On Production and Consumption Waste’ and Certain Legislative Acts of the Russian Federation” (“Law No. 495-FZ”) was enacted on 31 December 2025 to introduce the new EPR transition timeline for importers from non-EAEU countries.
14.01.2026
New U.S. sanctions
On 22 October 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a press release announcing the imposition of new sanctions against Russia. Below is an overview of the new restrictions and licenses.
27.10.2025
.jpg)
Changes in the regulation of the security of critical information infrastructure (CII)
In 2025, Federal Law No. 187-FZ “On the Security of Critical Information Infrastructure of the Russian Federation” dated 26 July 2017 was significantly amended to strengthen CII technology independence and security. The amendments, introduced by Federal Law No. 58-FZ dated 7 April 2025 (effective 1 September 2025) and Federal Law No. 325-FZ dated 31 July 2025 (effective 1 March 2026), determine CII entities and establish new obligations for them. We highlight the key developments that require companies to promptly adapt their approaches to categorizing CII facilities and building the software mix.
20.10.2025