Increasing complexity: Russian companies controlled by “unflriendly” entities could be sold only with consent of regional authorities 

June, 2023 - Vassily Rudomino, German Zakharov

The President of the Russian Federation instructed the Government to consider the opportunity of granting clearance for the sale of Russian legal entities controlled by “unfriendly” entities only with the consent of senior officials of the Russian regions where such entities are located. The Government should issue a report on this matter by June 15, 2023.

This new condition may substantially complicate and lengthen the process of transaction clearance by the Subcommittee of the Government Commission. Although this order is not yet a normative act, we believe that many ministries may proactively accept it as a guideline to follow, without waiting for a formal procedure to be developed. This may affect transactions that are already under consideration.


We will monitor the changes and keep you updated on any developments.


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Note: Please be aware that all information provided in this letter was taken from open sources. Neither ALRUD Law Firm, nor the author of this letter bear any liability for consequences of any decisions made in reliance upon this information.


If you have any questions, please contact the ALRUD Partners:

Vassily Rudomino

Senior Partner
Foreign Direct Investments
E: [email protected]

German Zakharov


Crisis Management, Economic Sanctions
and Compliance Practice,
Foreign Direct Investments
E: [email protected]





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