Decree 844, issued by the Russian president on November 8, 2023, has become the latest piece of legislation to form part of Russia’s countersanctions law. As highlighted in this report by Morgan Lewis, the decree lifts certain restrictions on transactions involving securities of non-Russian issuers, also referred to as foreign securities, when these transactions are conducted outside of Russia.
Prior to this decree, Russia imposed substantial limitations on dealings concerning foreign securities. Those following the development of Russia’s countersanctions law will recall that we previously covered the regulations set by Decree 844 for funds held in frozen type S bank accounts.
What appears significant about Decree 844 is the scope of its exemptions. While further details will need to be analyzed as the law is implemented, initial observations suggest a degree of flexibility, potentially favoring cross-border operations involving foreign securities.
It is crucial for corporations and legal professionals to stay abreast of these latest developments, considering the potential impact on handling international transactions and maintaining compliance under legal frameworks. The changes brought about by the enactment of Decree 844 add another layer of complexity to the already intricate world of international business law.
As the interpretations and applications of these regulations continue to unfold, close monitoring of subsequent modifications and related interpretations is warranted. This law not only impacts Russian corporations but can significantly influence international operation strategies of non-Russian entities as well.