On May 23, the Russian President signed a Decree authorizing the use of the U.S. assets in Russia (including, potentially, the assets of American companies and their Russian subsidiaries) to “compensate for damage caused by the U.S. Government and court decisions to the Russian Central Bank and Government assets”.

We have prepared a memo to analyze the following:
• Background of the Decree and expected approach to its enforcement.
• The procedure of making decisions about the assets’ expropriation, established by the Decree.
• Expected enforcement timeline.
• Scope and grades of risks for various categories of U.S. assets in Russia (funds on C type accounts, assets and property of U.S. companies continuing Russian business, securities owned by U.S investors in Russia, IP, etc.).

We also expect that a similar regulatory framework could be adopted and enforced for the EU and other G7 nations should they progress in implementation of the plan to direct the profits generated from immobilized Russian sovereign assets for assistance to Ukraine.

Taking into account that every U.S. company in Russia faces its individual situation and risks, we are ready to assist with elaboration of a strategy to protect the assets and mitigate the risks.

For more details on consequences of the presidential Decree, see our memo below.