Effective 01 September 2026, amendments to the Code of Administrative Offences of the Russian Federation (CAO RF)[1] will come into force, fundamentally changing the rules for bringing persons to administrative liability. Under the new regime, Russian citizens, foreign legal entities, and foreign nationals may be held liable for offences committed outside the territory of the Russian Federation.
Below are the key changes.
1. Extraterritorial Application of the CAO RF
Russian citizens, foreign nationals, stateless persons, and foreign legal entities may be subject to administrative liability for an offence committed outside the territory of the Russian Federation, provided that such acts are directed against the interests of the Russian Federation.
The legislator has significantly expanded the list of offences subject to extraterritorial application. The amendments primarily affect the digital environment and information-related activities.
The list of offences for which administrative liability will arise regardless of the place of commission includes:
- Article 13.14.1 – Unlawful obtaining of restricted-access information;
- Article 13.15 – Abuse of freedom of mass information;
- Article 13.36, Part 2 – Violation by an audiovisual service provider of the established procedure for distributing information harmful to children’s health and/or development;
- Article 13.37, Part 2 – Dissemination by an audiovisual service provider of information containing public calls for terrorist activity or materials publicly justifying terrorism;
- Article 13.48 – Violation of the federal statutory prohibition on publicly equating the goals, decisions, and actions of the USSR leadership, command, and military personnel with those of Nazi Germany, its command, and military personnel, as well as the European Axis powers during World War II, and denial of the decisive role of the Soviet people in defeating Nazi Germany and the humanitarian mission of the USSR in liberating European countries;
- Article 17.13 – Unlawful dissemination of information about protected persons;
- Article 19.34 – Violation of the procedure for the activities of a foreign agent;
- Article 20.1, Parts 3, 4 or 5 – Dissemination in information and telecommunications networks, including the internet, of expressing, in an indecent form, clear disrespect for society, the state, official state symbols of the Russian Federation, the Constitution of the Russian Federation, or state authorities;
- Article 20.3.1 – Incitement of hatred or enmity, as well as humiliation of human dignity;
- Article 20.3.2 – Public calls for actions aimed at violating the territorial integrity of the Russian Federation;
- Article 20.3.3 – Public actions aimed at discrediting the use of the Armed Forces of the Russian Federation;
- Article 20.3.4 – Calls for the introduction of restrictive measures against the Russian Federation, its citizens, or Russian legal entities;
- Article 20.29 – Production and dissemination of extremist materials;
- Article 20.33 – Participation in the activities of a foreign or international organisation whose activities have been declared undesirable in the territory of the Russian Federation.
2. Asset Seizure
Currently, seizure of assets as a provisional measure is imposed by courts only for two administrative offences (Articles 15.27.3 and 19.28 of the CAO RF).
The amendments broaden the scope of asset seizure, making it an available tool for all the offences listed above. Key novelties:
- Previously, the value of seized assets was tied to the amount of the fine. Now, the court may seize assets for any amount in respect of the aforementioned administrative offences.
- Seizure is primarily applied to funds in bank accounts and deposits. In their absence, seizure of other property is permitted.
- Assets belonging to any individual or legal entity (including foreign nationals and stateless persons) may be seized.
- Seizure may be ordered simultaneously with the initiation of proceedings upon a corresponding motion filed by the prosecutor or another authorised body.
3. Administrative Proceedings Procedure
If the person against whom proceedings are being conducted (for one of the “extraterritorial” offences) is located outside the territory of the Russian Federation, and proper notification of such person is impossible, an attorney shall be appointed on their behalf. The costs of the attorney shall be borne by the person subject to proceedings. The only exception is if the case is dismissed, consequently the costs of the attorney shall be covered from the federal budget.
The presence of the person subject to proceedings at the court hearing is not mandatory if they are abroad. The case may be heard in their absence, as their interests will be represented by the appointed attorney.
Consequently, a Russian citizen residing abroad may be held administratively liable for an extraterritorial administrative offence, and their assets and funds located in Russia may be seized as part of provisional measures.
[1] Federal Law No. 168-FZ dated 10 June 2026 “On Amendments to the Code of the Russian Federation on Administrative Offences”. URL:http://publication.pravo.gov.ru/document/0001202606100028?index=13.