On July 28, 2020, Draft Bill No. 996800 was introduced in the State Duma of Russia proposing additional Russian countersanctions (“Draft“).  The Draft proposes to introduce amendments to the Federal law No. 281-FZ dated December 30, 2006 “On special economic measures and coercive actions” that sets forth the legal framework for the Russian countersanctions regime. 

The Draft proposes the following principal provisions:

  • Application of the restrictive measures to the entities controlled by the sanctioned persons.  These controlled entities shall include the entities, which are more than 25% owned directly or indirectly (through the third parties) by the sanctioned persons. 

The Draft specifies that this expansion will be applied to the Ukrainian persons, with respect to which Russia previously introduced restrictive measures.

  • Clarifying the procedure of assets blocking, in particular: (1) requirement of payment operators to quarterly report on blocking of assets of the sanctioned persons, (2) authorization of the Central Bank of Russia to revoke licenses for the failure to fulfil the order to block the assets and (3) permission to the sanctioned persons to make operations for receiving and disposing of pensions, scholarships, allowances and other social payments guaranteed by the state, to pay taxes and penalties. 

The Draft also provides for the extensive list of organizations that are bound to block the assets of the sanctioned persons, which includes banks, insurers, non-state pension funds, market participants and some rather specific organizations, e.g. pawnshops and gambling organizers.

To become a law the Draft would need to pass 3 readings in the State Duma, be approved by the Federation Council, and then be signed by the Russian President.


Vladimir Zivkovic is a Director in Baker McKenzie Amsterdam’s Transfer Pricing team. He has 10+ years of experience in transfer pricing and value chain analysis. Vladimir started his career in Canada in 2008 and relocated to the Netherlands in 2011.