On September 9, the President's decree was published to introduce amendments to counter-sanctions Decrees No. 95 and No. 254, which, among other things, regulate payment of dividends to residents of unfriendly states by their Russian subsidiaries, and to Decree No. 138 on regulation of securities.

Let us remind you that the Sub-Commission generally had suspended the dividend approval process since the beginning of 2024 (though extraordinary permissions were issued) due to the discrepancies found between the special regime of dividend payment set by the Presidential decrees and the federal legislation on LLCs and JSCs on the payment terms requirement (the special regime presumes quarterly payments which are not possible under the federal legislation). The issue became the subject of disagreements for the Central Bank and the Ministry of Finance and could not be resolved for a long time.

The long-awaited amendments in the part of dividend payments may become a prologue to resumption of dividend applications consideration and approval.

For more details on the Presidential Decree, see our alert below.