In line with recent Presidential Decree No. 252 dated 03 May 2022, which introduced framework regulations on Russian counter-sanctions, the Russian Government adopted a list of specific persons targeted by Russian counter-sanctions (the “Designated Persons”) in Decree No. 851 dated 11 May 2022 (the “Decree”). There are 31 companies in the list of the Designated Persons, which mostly include former foreign subsidiaries of Russia’s Gazprom and companies formerly controlled by Gazprom.  

The list of the Designated Persons includes 31 companies from the USA, Britain, European countries and Singapore. In particular, the Designated Persons include Gazprom Germania GmbH, Gazprom Marketing & Trading Ltd. and other former foreign subsidiaries of Russia’s own Gazprom as well as companies formerly controlled by Gazprom, such as entities within the VEMEX and Wingas/WIEH/WIEE groups. All Designated Persons seem to have been involved with the supply and sale of Russian gas.

According to Decree No. 252, all Russian companies (including Russian branches and subsidiaries of foreign companies), individuals and state authorities may no longer enter into transactions with the Designated Persons, fulfill existing obligations vis-à-vis them, perform financial transactions and export products or raw materials benefitting the Designated Persons. The Decree of the Russian Government established additional criteria for the prohibited transactions with the Designated Persons. In particular, such prohibited transactions include:

• transactions benefitting the Designated Persons; 
• transactions aimed at providing access to the Russian ports to ships owned or chartered by the Designated Persons, in their interest or at their instruction; 
• transactions including payments, securities transactions with the participation of or for the benefit of the Designated Persons.

The Russian Ministry of Finances is entitled to make proposals to the Russian Government on amendments to the list of the Designated Persons and the issuance of temporary licenses (permits) to authorize individual transactions with the Designated Persons as an exception from the sanctions regime.

Although now the list of the Designated Persons seems to focus on the companies formerly associated with Gazprom, this list may be extended further. 

We will keep you informed on the relevant developments in due course.