The President of the Russian Federation has extended the status of “unfriendly” persons and “foreign creditors” to individuals who have not provided proof of citizenship or a residence permit in the Russian Federation, or of citizenship or a residence permit in a “friendly” state
Now, in accordance with Decree No. 816 of November 5, 2026, individuals from foreign states who commit unfriendly acts against the Russian Federation, Russian legal entities, and Russian individuals (“Unfriendly State”) include, among others, individuals who have not provided any of the following documents:
- a document certifying Russian citizenship or a residence permit in the Russian Federation;
- a document certifying citizenship (nationality) of a foreign state that is not an “Unfriendly State” (“Friendly State”), a residence permit, or another document confirming the right to permanent residence in the territory of a Friendly State.
The relevant clarifications have been incorporated into six counter-sanctions decrees of the President of the Russian Federation: No. 81 of March 1, 2022; No. 95 of March 5, 2022 (regarding the clarification of the term “foreign creditors”); No. 254 of May 4, 2022 (regarding the clarification of the term “foreign creditors”); No. 618 of September 8, 2022 (“Decree 618”); No. 737 dated October 15, 2022; No. 198 dated March 19, 2024.
At the same time, the procedure for issuing official clarifications regarding Decree No. 618 has been changed. Clarifications regarding the application of the new provision on individuals who have not submitted documents are now provided by the Bank of Russia, while clarifications on other issues related to the application of Decree No. 618 are provided by the Ministry of Finance of the Russian Federation. Previously, only the Ministry of Finance of the Russian Federation had the authority to provide clarifications regarding Decree 618 in its entirety.
