On September 8, President Putin signed an Executive Order restricting residents of “unfriendly jurisdictions” to conduct transactions with the shares in Russian limited liability companies (LLCs).

These residents even with insignificant assets in Russia planning to restructure or sell their businesses will be required to get approval of the sub-Commission of the Government Commission for Foreign Investment Control.

The order will significantly complicate the process of restructuring foreign assets in Russia and the exit of multinationals from the market, as most of foreign investors have structured their assets as LLCs.