Yesterday, on 8 September 2022, Decree No. 618 of the President of the Russian Federation (the “Decree”) was published. The Decree provides that permission from the Government Commission needs to be obtained for any transactions with membership interests in limited liability companies (“LLCs”) that have as participants foreign persons “associated with states undertaking unfriendly actions with respect to the Russian Federation” .
A similar procedure has been in effect since March of this year for transactions with real estate and securities, but it will not be applied to membership interests of LLCs: the Decree establishes that the Russian Government must, within a ten-day period, establish a procedure for the Government Commission to issue permissions. It is also stipulated that the Russian Ministry of Finance has the right to provide official clarifications with respect to issues of applying the Decree.
 The Government Commission for Control Over the Making of Foreign Investments in the Russian Federation.
 The list of states is established in the Russian Government’s Order No. 430-r dated 5 March 2022.