In order to reduce external sanctions exposure the list of information which listed companies are authorized not to disclose has been compiled.

This list appears in the Resolution of the Government of the Russian Federation dated 04.04.2019 No. 400 “On specifics of disclosing and providing information to be disclosed and provided, as required by the Federal law “On joint-stock companies” and the Federal law “On the securities market”.

Under new rules listed companies will be able to quickly counteract against increased sanction pressure and remove their third-parties and partners from the “secondary” sanctions exposure. This is due to the CAATSA law adopted in the USA in 2017, according to which companies from third countries cooperating with entities under sanctions may also be subjects to restrictions.

Listed companies are authorized not to disclose or disclose to a limited extent the following data:

  • management
  • transactions
  • ownership structure
  • shareholders, including minority and majority
  • partners
  • financial investment
  • risks and their assessment
  • corporate disputes
  • third-parties including their industry and geographical coverage.

Credit institutions are entitled not to disclose the following data:

  • on transactions in foreign currency
  • on distribution of funds on accounts depending on the client category
  • on business activity segments.

Listed companies are authorized not to disclose the mentioned data if:

  • information on individuals under sanctions may lead to restrictions against a listed company and other persons
  • company itself is under sanctions
  • listed company is a bank serving the state defense order
  • details of defense orders or military-technical cooperation are unveiling
  • information relates to company’s employees under sanctions or a bank serving defense enterprises.

At the same time, listed companies are not exempted from the obligation to disclose this information to the Central Bank of the Russian Federation – the regulator.


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