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Foreign shareholders of large companies may be restricted in their corporate rights

On 17 January 2023, the President signed Decree No. 16 “On an interim procedure for the governing bodies of certain Russian companies to adopt resolutions.”

The Decree establishes an interim procedure for Russian companies in whose share capital and governing bodies participate both foreign persons from “unfriendly” states and Russian persons who are subject to sanctions’ restrictions (or such Russian persons are the ultimate beneficiaries of such companies). We have highlighted some conditions set forth in the Decree that seemed the most interesting to us.

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