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On August 4, 2023, Federal Law No. 470-FZ “On the Specifics of Regulation of Corporate Relations in Companies That Constitute an Economically Significant Organization” (hereinafter, the “Law”) was published. The Law introduces mechanisms to exclude “unfriendly” foreign holding companies from the chain of ownership of Russian Economically Significant Organizations (ESOs). The Law comes into force on September 4, 2023.

A foreign holding company is defined as a foreign legal entity that is associated with “unfriendly” foreign states and owns at least 50% of the voting shares (participatory interest) of the ESO.