He points out that as permitted by Russian corporate law, a number of Russian companies pay dividends not only at the end of the year, but also on a half-year or quarterly basis.

Restrictions on the payment of dividends by Russian LLCs and partnerships to foreign shareholders were established in May by a presidential decree. Specifically, Decree No. 95 of March 5, 2022 prohibited JSCs from paying dividends to non-residents from "unfriendly” countries.

By default, a Russian firm deciding to distribute profits must pay any dividends owed to non-residents from "unfriendly" states into C-type bank accounts, from which funds cannot be withdrawn, but can only be used for a limited range of purposes, including paying taxes or buying OFZs (Russian government bonds). Dividend payments to unblocked accounts require the permission of the Bank of Russia (for payments by banks and financial institutions) or the Ministry of Finance (for payments by other Russian companies). A subcommittee of the Ministry of Finance has just outlined the criteria for issuing such permits, says Maxim Kuleshov.

More details are available here.