Russian counter measures : recent developments (update June 1st, 2022)


Russia adopted a series of counter measures in May.

The President issued a decree establishing a special procedure for performance of obligations towards foreign intellectual property owners. The decree targets a range of IP owners establishing that the payments are to be made in roubles to a special account in an authorized Russian bank. The decree allows making payments to foreign bank accounts of the IP owner only after authorization of a special Governmental Commission.

The Government determined a list of foreign entities targeted by sanctions. The list was prepared pursuant to a presidential decree No. 252 dated 3 May 2022. For more details on this decree, please refer to our Legal Alert dated 3 May 2022.

Additionally, draft law on external administration of foreign companies was adopted in the first reading. Please refer to our Legal Alert dated 13 April 2022 for more details on this legal initiative.

Draft law on criminalization of enforcement of sanctions might be considered in the first reading before 9 June 2022, according to the information published on the official website of the State Duma. Please refer to our Legal Alert dated 7 April 2022 for more details on this legal initiative.

Russian counter measures

  1. President issued decree on temporary procedure of execution of obligations towards certain IP owners No. 322 dated 27 May 2022.

The new decree establishes restriction on the payment by Russian residents (debtors) of fees (royalties) under license, sub-license, IP management and other contracts related to the use of IP to foreign IP owners.

The decree targets the following IP owners:

►incorporated in a jurisdiction considered as unfriendly by Russia (including France) or are Russian subsidiaries of such foreign IP owners,

►publicly support foreign sanctions against Russia,

►have prohibited the use of such IP in Russia or in relation to certain Russian persons/entities,

►have suspended their activities in Russia,

►have publicly discredited Russian army, or

►have insulted in the Internet Russian state or public interests.

Entities controlled by Russian persons are not targeted in case they disclosed such control to Russian tax authorities.

Royalties and related payments are to be made in RUB to a type “O” bank account opened in a Russian authorized bank. Russian Governmental Commission can authorize the transfer of funds from the bank account of type “O” to the foreign bank account of the IP owner.

The restriction does not apply to:

►Payments not exceeding RUB 100,000.00 that are made by individuals for their private needs,

►Foreign IP owners, which duly perform their IP contracts with Russian residents,

►IP contracts concluded between Russian residents and foreign IP owners on the importation or production of medicines, medical devices, industrial, agricultural and food products in Russia,

►IP contracts concluded between Russian residents and foreign IP owners on the provision of communication services or traffic transmission services,

IP contracts concluded between Russian residents and foreign IP owners on the creation or use in Russia of databases, information systems, data processing centers and software for computers.

2. Government issued a list of persons under sanctions

On 11 May 2022, the Russian Government prepared a list of persons under sanctions.

The list includes:

►Gazprom Germania GmbH

►Astora GmbH

►ZGG – Zarubezhgazneftehim Trading GmbH


►WIEE Hungary Kft.

►WIEE Bulgaria EOOD






►WINGAS Sales GmbH

►WINGAS Holding GmbH

►Industriekraftwerk Greifs wald GmbH


►WINGAS Benelux s.r.l.

►Gazprom Marketing & Trading Ltd.

►Gazprom Global LNG Ltd.

►Gazprom Marketing & Trading France SAS

►Gazprom Marketing & Trading USA Inc.

►Gazprom Marketing & Trading Switzerland AG

►Gazprom Marketing & Trading Singapore PTE. Ltd.

►Gazprom Marketing & Trading Retail Ltd.

►Gazprom Mex (UK) 1 Ltd.

►Gazprom Mex (UK) 2 Ltd.

►PremiumGas S.p.A.

►VEMEX s.r.o.




The list was adopted pursuant to Presidential Decree No. 252 dated 3 May 2022 “On Special Economic Measures Countering Unfriendly Acts of Certain Foreign States and International Organizations”. As a reminder, the decree establishes the following restrictions:

►Ban for federal and regional governmental bodies, entities and individuals under the Russian jurisdiction to:

+ Perform any actions, including conclusion of foreign trade contracts, with entities and individuals subject to Russian special economic measures. The ban also extends to any engagement with organizations controlled by said targeted persons;

+ Fulfill obligations under executed transactions, including under concluded foreign trade contracts, if such obligations have not been (fully) performed.

►Ban on exportation of products and / or raw materials manufactured and / or extracted on the Russian territory, if such products and / or raw materials are supplied to persons under sanctions or by such persons in favor of third persons.

Proposed legislation

3. Draft law on external administration of foreign companies adopted in the first reading.

On 24 May 2022, the State Duma adopted Draft Law “On External Administration of Companies” in the first reading.

As a reminder, this draft law was introduced as an alternative to an initial, more rigid legal initiative, also known as the nationalization law. This draft law still has certain inconsistencies and unclear provisions that either have to be clarified for further readings in the Duma or will be applied at the discretion of the courts and the specific commission once the initiative becomes law. In particular the draft law primarily targets companies of significant importance for Russian economy but also allows a specific commission to determine a company as significant on a case-by-case basis.

For more information on this draft law, please refer to our legal alert dated 13 April.

We are actively following the developments related to those issues and are fully prepared to advise our clients.

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