Strategic companies and banks — transactions only by Presidential permit
For listed strategic companies, energy projects and banks, the sub-commission is not enough: transactions with their shares involving unfriendly persons need a Presidential permit.
What it does
Decree No. 520 prohibits, without a special permit of the President, transactions by persons of unfriendly states with securities and participation interests in companies on lists approved under it — strategic enterprises, participants of production-sharing agreements and energy projects, and banks. For these companies the ordinary sub-commission procedure under Decrees No. 81 and No. 618 does not apply; the permit comes from the President, on the Government Commission's proposal.
Status, October 2026
In force; the lists of companies are amended from time to time. Before any transaction, check whether the target or its parent is listed.
Guides that discuss it
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.
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.