Insights
2026-07-15 00:00 Asset Tracing &amp Recovery

What should foreign clients know about third-party disclosure orders in Russian proceedings under Article 46 of Law 229-FZ?

Under Russian enforcement proceedings legislation, Article 46 of Law 229-FZ empowers the Federal Bailiff Service (FSSP) to compel third parties — including banks, registries, employers, and commercial counterparties — to disclose information about a debtor's assets. For a foreign creditor holding an enforceable Russian judgment or award, this mechanism is one of the most practical tools for locating assets before or during enforcement. It does not require a separate court application; the bailiff issues the request directly on the basis of an open enforcement file.

Article 46 of Law 229-FZ sits within the broader framework of Russian enforcement proceedings law and places a legal obligation on the recipient of a bailiff's request to respond within the prescribed period. Non-compliance exposes the third party to administrative liability. The provision covers both monetary assets — bank account balances, securities holdings, outstanding receivables — and non-monetary property rights, including registered real estate and participatory interests in legal entities. Requests directed at the Rosreestr property registry, the Federal Tax Service, and the Central Bank of Russia's reporting systems are among the most commonly used routes in practice.

For a foreign creditor, the practical significance of this instrument lies in its administrative character: it operates independently of any additional litigation, provided that an enforcement order has been issued by a Russian bailiff. Where the debtor is a corporate entity, third-party disclosure requests can map intercompany transfers, identify pledged assets, and reveal register-held interests that would not appear on a balance sheet. Creditors who engage Russian enforcement counsel early in the process are better positioned to direct the FSSP's requests towards the asset classes most likely to yield recovery. For guidance on the full procedural sequence, see Third-Party Disclosure Orders in Russian Proceedings and A Practical Guide to Third-Party Disclosure Orders in the firm's Asset Tracing & Recovery practice resources.

If you are seeking to enforce a judgment or arbitral award against a Russian debtor, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

— Elizaveta Razina Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/

Elizaveta Razina leads the firm's intellectual property practice, representing foreign trademark owners in infringement proceedings before Russian state courts and the IP Court. She advises on anti-counterfeiting strategy and parallel import controls, and supports the firm's asset tracing work on recovery-focused matters.

This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.