On 1 July 2025, Presidential Decree No. 436* “On Additional Guarantees of the Rights of Foreign Investors” was published and entered into force. The decree is meant to protect foreign investors’ interests, given the ongoing economic restrictions and counter-sanctions in the Russian Federation (the “Decree No. 436”).

Decree No. 436* grants foreign investors — including those from “unfriendly” jurisdictions — the right to invest in the Russian Federation irrespective of the restrictions imposed by several counter-sanctions decrees issued by the President in 2022–2023.

In certain cases, foreign investors can now buy securities on the Russian market without needing prior approval from the relevant Russian bodies.

A new type of special account has been introduced for such investments — the “In” account. This account can be credited with roubles or foreign currency sent from the foreign investor’s bank abroad, specifically for investing in Russia. in the Russian Federation. It’s also used to receive any income from those investments. Crucially, foreign investors are allowed to transfer money from their “In” account back overseas at any time, without needing additional approval.

The provisions of Decree No. 436* apply to:

1. Transactions involving Russian securities (incl. initial placements, trading, and payments);
2. Deposits in Russian credit institutions;
3. Transactions with derivative financial instruments conducted by professional market participants on behalf of foreign investors.

Decree No. 436*, therefore, introduces a mechanism allowing foreign persons — regardless of their country of origin — to make new investments in the Russian Federation and freely transfer funds in and out of the Russian market. Previously, such transactions were subject to significant restrictions.

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On the same day, 1 July 2025, Presidential Decree No. 435* “On Amendments to Certain Decrees of the President of the Russian Federation” (the “Decree No. 435”) also came into effect. This decree partially relaxes restrictions on transactions involving real estate, securities, and shares owned by individuals from “unfriendly” jurisdictions. Specifically:

• No state approval is required under Decree No. 81 for gratuitous real estate transactions between spouses or close relatives, provided only one party to the transaction is a citizen of an “unfriendly” foreign state.
• The prohibition established by Decree No. 520 does not apply to gratuitous transactions involving securities or shares between spouses or close relatives, again provided that only one party is a citizen of an “unfriendly” foreign state.

This points to a careful, gradual loosening of some counter-sanctions restrictions. Nonetheless, the provisions of the previously introduced decrees of the President of the Russian Federation in 2022-2023, unaffected by the decrees noted above, remain in force. So, restrictions on investors from “unfriendly” countries are still in place to a large extent.

* In Russian

Publication is also available in Japanese and Russian.

Authors:

Maxim Boulba, Partner

Elena Andrianova, Senior Associate

Ksenia Voloshchenko, Associate