On 8 September 2022, the Russian president signed a decree imposing restrictions on the sale of shares in the share capital of a Russian legal entity, like an OOO. This decree will be implemented both in relation to foreign natural persons, and to companies owned by citizens of countries defined as hostile. These transactions may be carried out following special authorizations issued, between residents of ‘hostile’ states and Russian residents, by the Government Commission for the Control of Foreign Investments in the Russian Federation. Furthermore, it follows from the decree that, with the approval of the commission, not only transactions involving the sale of shares in an OOO by persons from ‘hostile’ countries to Russian residents will be possible, but also transactions involving the purchase by residents of hostile states of shares in an OOO from Russians, as well as the purchase by residents of hostile countries of shares in a Russian OOO from residents of friendly or neutral countries.This decree will not apply to a limited number of transactions described in the previous presidential decree of August 5, which prohibited, at least until the end of 2022, the sale of shares in Russian strategic companies by investors from ‘hostile’ countries, oil refineries, fuel and energy equipment manufacturers and banks. The decree also formally exempts residents of ‘hostile’ countries that are controlled by Russian citizens or legal entities, if these beneficiaries have disclosed all relevant information on control to the Russian tax authorities.