Courts may terminate an unfriendly investor's buy-back option
A new Article 20.1 of the Foreign Investment Law lets Russian courts terminate the right of a departed unfriendly investor to buy back the asset it sold.
What it does
Federal Law No. 319-FZ added Article 20.1 to the Foreign Investment Law. Many exits approved by the Government Commission since 2022 left the seller an option to buy the Russian business back later. The new article gives Russian courts a procedure to terminate such buy-back rights on the application of the buyer or another interested person. For a Western group, a buy-back option negotiated into an exit can no longer be treated as a reliable route back.
Status, October 2026
In force since August 2026; court practice under the new article is only beginning. See the exit-cost guide.
Guides that discuss it
How Russian counter-sanctions work: decrees, the Government Commission and the Bank of Russia
Who issues what, which instruments actually bind a bank, and why the answer to a simple question is usually spread across four documents.
The cost of exiting Russia in 2026: the 60% discount, the 35% contribution and the end of the buy-back
What a Western seller actually receives after the sub-commission's conditions, how long a permit takes, and what Law 319-FZ did to buy-back options.
Decree No. 618: getting a Government Commission permit for a transaction with a Russian LLC interest
What needs a permit, what does not (including the 2025 and 2026 Ministry of Finance clarifications), what goes in the file, how long it takes and what happens at the notary.