Russian Supreme Court Issues Guidance on the Application of Countersanctions Legislation
The Supreme Court of the Russian Federation has published a thematic review outlining 22 legal positions on the application of Russia’s countersanctions framework.
The review sends a clear signal that transactions designed to circumvent restrictive measures may be deemed invalid. Among the practices highlighted are the artificial splitting of payments to bypass the monthly RUB 10 million cap on loan repayments and the use of sham assignments of claims to Russian residents as a means of transferring funds abroad without using Type “C” accounts. The document also sets out the Court’s approach to compulsory licensing.
These legal positions are expected to shape future court practice in disputes involving special economic measures. Throughout the review, the Supreme Court repeatedly emphasizes the need to protect public interests, including financial stability, national security, and oversight of asset and payment flows.
Central Bank Reports Record Holdings on Non-Resident Accounts
According to media reports citing data from the Central Bank of Russia, assets held by non-residents through Russian brokerage accounts exceeded RUB 2.6 trillion in the first quarter of 2026. This represents a 9% increase year-on-year and marks the highest level since the third quarter of 2021.
Most of these assets are held by corporate investors. At the same time, more than one-third of transactions are reportedly carried out by brokers on behalf of clients that are formally non-resident but ultimately controlled by Russian beneficiaries.
Strong yields on ruble-denominated instruments, combined with the appreciation of the ruble and a tight monetary policy environment, continue to attract foreign capital. Media reports also suggest that several international investment funds are preparing contingency plans for a rapid return to Russian assets should sanctions be eased.
Central Bank Expands the Scope of Type “C” Accounts
The Central Bank of Russia has introduced changes expanding the range of transactions permitted through Type “C” accounts.
One of the key developments is the creation of a mechanism allowing the return of previously credited securities-related payments to investors, including non-residents who are not considered foreign creditors under Presidential Decree No. 95 of 5 March 2022.
The mechanism applies provided that sanctioned creditors did not hold the relevant securities after 1 March 2022 or that the transactions were carried out under special presidential authorizations.
The amendments are intended to ease unnecessary restrictions, simplify payments on securities issued by Russian companies, and reduce operational barriers for bona fide market participants.
Russia Clarifies FAS Notification Rules for Foreign Investments in Strategic Companies
The Russian Government has approved amendments to the rules governing notifications related to foreign investments.
The updated regulations clarify that the Federal Antimonopoly Service (FAS Russia) is the authority responsible for overseeing foreign investment transactions. They also expand the list of documents required for relevant transactions, which now includes information on beneficiaries, beneficial owners, and controlling persons.
The changes are aimed at aligning existing procedures with Federal Law No. 51 of 8 March 2026, which strengthens oversight of foreign investments in strategically important sectors of the Russian economy.
State Duma Approves Law Allowing Foreign Companies to Conduct Commodity Market Research for Tax Purposes
The State Duma has adopted amendments allowing foreign companies, as well as Russian companies with more than 20% non-resident ownership, to conduct commodity market research where the results are used for tax or customs and tariff regulation purposes.
The exemption will remain in force until 1 September 2028.
The initiative was introduced by the Russian Government to ensure continued monitoring of global prices for oil, gas, and hydrocarbons when calculating export duties and determining benchmark prices for taxation and customs purposes.
By the end of the transition period, Russia expects to establish domestic commodity market research providers and develop its own system of national price benchmarks.