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On July 28, 2020, in the State Duma of Russia was introduced the Draft Bill No. 996800 proposing additional Russian countersanctions (“Draft“).  The Draft proposes to introduce amendments to the Federal law No. 281-FZ dated December 30, 2006 “On special economic measures and coercive actions” that sets forth the legal framework for the Russian countersanctions regime.

The Draft proposes the following principal provisions:

  • Application of the restrictive measures to the entities controlled by the sanctioned persons.  These controlled entities shall include the entities, which are more than 25% owned directly or indirectly (through the third parties) by the sanctioned persons.

The Draft specifies that this expansion will be applied to the Ukrainian persons, with respect to which Russia previously introduced restrictive measures.

  • Clarifying the procedure of assets blocking, in particular: (1) requirement of payment operators to quarterly report on blocking of assets of the sanctioned persons, (2) authorization of the Central Bank of Russia to revoke licenses for the failure to fulfil the order to block the assets and (3) permission to the sanctioned persons to make operations for receiving and disposing of pensions, scholarships, allowances and other social payments guaranteed by the state, to pay taxes and penalties.

The Draft also provides for the extensive list of organizations that are bound to block the assets of the sanctioned persons, which includes banks, insurers, non-state pension funds, market participants and some rather specific organizations, e.g. pawnshops and gambling organizers.

To become a law the Draft would need to pass 3 readings in the State Duma, be approved by the Federation Council, and then be signed by the Russian President.


Vladimir Efremov is a partner in Baker McKenzie's Moscow office. His practice focuses on cross-border tax planning and tax-efficient structuring of capital transactions in and outside of Russia. Mr. Efremov specialises in international trade issues, WTO, domestic and cross-border, direct and indirect taxation, FCPA and compliance audits. He also specialises in the areas of customs and currency regulations.


Alexander Bychkov is a partner in Baker McKenzie's Moscow office. Alexander Bychkov is the co-head of the Firm’s CIS Tax Practice Group and the head of the CIS International Trade and Customs group, which includes professionals working in the Moscow, St. Petersburg, Kyiv and Almaty offices. In addition, he is a member of the Firm’s Pharmaceuticals & Healthcare group. Since 2006 Mr. Bychkov has been consistently recognized as one of the leading professionals in the tax field within Russia and across the CIS. His practice is recognized by Chambers and International Tax Review.