Decree No. 81 · 1 March 2022

Permits for transactions with persons of unfriendly states

The decree that made the Government Commission the gatekeeper. Rouble loans, securities and real estate deals with persons of unfriendly states need its permit; it also capped the export of cash foreign currency.

What it does

Decree No. 81 requires a permit of the Government Commission for Control over Foreign Investment for transactions between residents and persons of unfriendly states that involve rouble loans granted to such persons, and that establish or terminate ownership of securities and real estate. The procedure is set by Government Resolution No. 295; the sub-commission decides. Participation interests in LLCs were added separately by Decree No. 618, and the two are applied together. The decree also limited the export of cash foreign currency to the equivalent of USD 10,000 per person.

The exception for persons controlled by Russian owners who have disclosed control to the tax authorities (paragraph 12 of Decree No. 95) and for friendly control established before 1 March 2022 (Decree No. 254) applies to paragraph 1(a) of this decree.

Status, October 2026

In force, without an end date. Joint-stock company shares, Russian securities and real estate remain inside the permit regime; exits are approved on the published conditions of the Government Commission.

Operations that rest on it

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.

Intra-group loans with a Russian subsidiary: granting, repaying and the permit line

Which direction of lending is free, which needs a permit, how repayment to a Western lender works above RUB 10 million, and the new RUB 30 million limit for capital contributions.

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.

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