OBS_VALUE: As from 2023 the law introduces mechanisms to exclude foreign holding companies from “unfriendly” states from the chain of ownership of Russian economically significant organizations (ESO), if such foreign companies own at least 50% of the voting shares of the ESO. ESOs are defined as Russian companies essential for ensuring economic sovereignty and economic security, the list of such companies is to be compiled by the RF Government. Criteria for considering the company an ESO are quite broad. The inclusion of a company in the list of ESOs may entail, inter alia, the following consequences: - suspension of the corporate rights of the foreign holding company in respect of the ESO based on a court decision; - receipt of ESO’s dividends by Russian beneficiaries directly on the basis of a court decision, provided that such persons perform the obligation to assume direct ownership of ESO shares (interests); - establishment of a company through a judicial proceeding with the transfer thereto of the rights of the foreign holding company to the shares (interests in the authorized capital) of the ESO.  See Federal Law On the peculiarities of regulating corporate relations in business companies that are economically significant organizations, Федеральный закон от 04.08.2023 № 470-ФЗ Об особенностях регулирования корпоративных отношений в хозяйственных обществах, являющихся экономически значимыми организациями, http://publication.pravo.gov.ru/document/0001202308040071 As from 2022, the RF Central Bank put a temporary ban for brokers on the execution of transactions for the sale of securities on behalf of non-residents (http://www.cbr.ru/press/pr/?file=28022022_072328SUP_MEAS28022022_072619.htm). Respective resolution does not specify any time limit for this prohibition. Also, Governmental preliminary approval is required for transactions whereby a foreign state or an international organisation, or any organisation controlled by the foreign state or by the international organisation, acquires direct or indirect control over 25% of shares in any Russian company. In order to ensure the country's defense and state security, by decision of the supervising authority, transactions made by foreign investors in relation to Russian entities are subject to prior approval in the manner prescribed by the Law On Foreign Investments in Companies of Strategic Importance. Citizens of the Russian Federation who have other citizenship and organizations under the control of foreign investors, including those established on the territory of the Russian Federation, are also considered as foreign investors. The same approval requirement applies to any foreign investor that acquires control over 50% of shares of a company of strategic importance. As from 2017, foreign legal entities and organizations (including their Russian subsidiaries) that do not disclose information about their beneficiaries/controlling entities to Russian state authorities are precluded from carrying out transactions that lead to establishing control over companies of strategic importance. As from 2022, the law establishes certain restrictions applicable to the entities that are considered foreign agents. A foreign agent, in accordance with the law, could be a Russian or foreign legal entity who has received support from abroad or is under foreign influence, and engages in certain activities. Such activities include distribution of printed, audio, audiovisual and other messages and materials intended for a public use (including using the Internet), and (or) participation in the creation of these messages and materials, or financing of such activities. A foreign agent is not entitled to operate certain objects of critical information infrastructure or invest in Russian strategic entreprises (http://duma.gov.ru/news/54760/)