Permits for transactions with Russian LLC interests
Any transaction that creates, changes or ends rights to an interest in a Russian LLC with an unfriendly party needs a sub-commission permit — with no monetary threshold.
What it does
Decree No. 618 made subject to a permit of the Government Commission's sub-commission every transaction that directly or indirectly establishes, changes or terminates rights to a participation interest in a Russian limited liability company, or rights to determine its management, where a party is connected with an unfriendly state. Sale, gift, pledge, trust management, options, withdrawal of a participant and shareholder agreements shifting control are all covered. Notaries refuse to certify, and the tax registrar refuses to register, without the permit.
Exemptions: disclosed Russian control, friendly control predating 1 March 2022, general permits, and the cases removed by Ministry of Finance Clarifications No. 4 (2025) and No. 5 (1 July 2026). The permit guide sets out the procedure.
Status, October 2026
In force, without an end date.
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.
The Russian-control exception: disclosing control to the Federal Tax Service and what it unlocks
The one lawful way out of the “unfriendly” regime for a foreign company owned by Russians — the CFC notification, the tax office confirmation under Letter ShYu-4-13/13043@, and the decrees it switches off.
Liquidating a Russian subsidiary with an unfriendly shareholder: permits, payouts and timing
Winding up instead of selling — whether the liquidation decision needs a permit, how the liquidation proceeds reach the parent (they mostly do not), the tax on the way out and a realistic timetable.