Federal Bailiff Service issues guidance on international letters rogatory directed at Russian authorities

New guidance from Russia's Federal Bailiff Service, issued in late 2025, materially changes the administrative pathway for international letters rogatory directed at Russian authorities. For foreign creditors whose asset-tracing efforts depend on compelled disclosure from Russian banks, registries, and state bodies, the guidance formalises requirements that were previously left to individual enforcement officers to interpret. The shift has immediate operational consequences: requests that met prior informal standards may now be returned unprocessed, resetting timelines that are already measured in months rather than weeks.

Until recently, the Federal Bailiff Service — Russia's principal civil enforcement body — processed incoming international letters rogatory under a patchwork of bilateral treaty obligations, internal circulars, and officer-level discretion. The new guidance consolidates these into a single administrative framework, establishing for the first time a standardised checklist of formal requirements that a letter rogatory must satisfy before it is accepted for execution by an enforcement officer.

The most consequential changes concern three areas. First, the guidance requires that all incoming letters rogatory be accompanied by a certified translation into Russian, authenticated by a method recognised under the applicable bilateral treaty or, where no treaty applies, by apostille. This is not new as a principle, but the guidance is explicit that defective translations — including translations that omit procedural recitals present in the original — will result in automatic return of the request without substantive review.

Second, the guidance introduces a formal acknowledgement stage: the receiving enforcement office must now issue written confirmation that the letter rogatory has been accepted or, if defective, a reasoned written notice of return. Foreign counsel previously encountered situations where requests entered the system without any acknowledgement and without any mechanism for follow-up. The guidance establishes a fixed response window, though the duration of that window reflects administrative timelines under Russian procedural law, and foreign creditors should not assume it aligns with the urgency their own proceedings may impose.

Third, the guidance addresses the treatment of letters rogatory submitted through channels not contemplated by the applicable treaty. Requests routed through diplomatic channels where a direct court-to-court channel is available — or vice versa — will now be formally rejected rather than redirected. For creditors tracing assets across Russia, CIS member states, and EAEU jurisdictions, this distinction is operationally significant: the correct channel varies by treaty and, in some cases, by the type of information sought.

Note: A letter rogatory returned for formal defects does not toll limitation periods under Russian civil procedure. Foreign creditors whose recovery timelines are tight should treat a defective or delayed submission as a material risk to their enforcement strategy, not merely an administrative inconvenience.

If your asset-tracing efforts include compelled disclosure requests directed at Russian authorities, the revised requirements may affect requests already in preparation — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The guidance affects any foreign party that relies on international letters rogatory as part of a Russian enforcement or asset-tracing strategy. In practice, the most exposed are foreign trade creditors, institutional creditors holding security over Russian assets, and distressed investors seeking to identify and freeze assets in advance of, or concurrent with, Russian insolvency proceedings.

Creditors operating under bilateral treaties with Russia — including many European states, CIS member states, and a number of Asian jurisdictions — will find the guidance directly applicable to their requests. For creditors in jurisdictions without a bilateral treaty, the guidance tightens the already narrow pathway: requests will now be evaluated more rigorously against the Hague conventions and, where those do not apply, against Russian civil procedure rules on foreign judicial assistance.

The change is also relevant for foreign law firms instructing Russian counsel on asset-tracing mandates. The guidance shifts responsibility for formal compliance squarely onto the submitting party. An otherwise well-founded request — correctly identifying assets, properly authorised by the foreign court — can now be defeated on translation or channel grounds before an enforcement officer considers its substance. Firms coordinating cross-border recovery strategies that include a Russian leg should treat the new formal requirements as a condition precedent, not as a post-submission concern.

"The guidance removes the discretion that individual enforcement officers previously exercised on incoming requests — which cuts both ways. Creditors with well-prepared requests gain predictability; those with informal submissions lose the benefit of the doubt." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For creditors whose proceedings engage both Russian insolvency law and international letters rogatory procedure — a combination that arises regularly when a debtor holds assets in multiple jurisdictions — the interaction between the two frameworks warrants careful sequencing. Further analysis of the creditor-side position in Russian insolvency proceedings is available in the firm's Restructuring & Insolvency practice materials.

The guidance is effective and applies to letters rogatory currently in preparation as well as those that have been submitted but not yet accepted. Foreign creditors and their advisers should treat the following as immediate review points.

Review translation quality and authentication. Any letter rogatory currently drafted for submission to Russian authorities should be reviewed against the new formal checklist before filing. Translations must be complete — including all recitals and procedural formalities in the original — and authenticated by the method the applicable treaty or Russian civil procedure rules prescribe. A translation that was adequate under prior informal practice may no longer be sufficient.

Confirm the correct submission channel. The applicable bilateral treaty determines whether a request passes through a central authority, through diplomatic channels, or directly between designated courts or enforcement bodies. The guidance eliminates the tolerance for channel ambiguity that previously existed. Counsel should confirm the correct channel before submission, not as an afterthought.

Build in a formal response window. The guidance establishes that enforcement offices will now issue written acceptance or return notices within an administrative window. Foreign creditors should build this window into their enforcement timetables — particularly where asset-tracing results are needed to support parallel freezing applications or insolvency claims with hard procedural deadlines.

For creditors who have already submitted requests through Russian channels, a proactive enquiry to the receiving enforcement office — through Russian counsel — is advisable to determine whether the request has been accepted or returned under the new requirements.

For a detailed treatment of the procedural framework governing letters rogatory directed at Russian authorities, see International letters rogatory directed at Russian authorities: procedural overview and the firm's comparative analysis of international letters rogatory frameworks.

The firm's Asset Tracing & Recovery practice advises foreign creditors on the full sequence of asset-identification, preservation, and recovery steps under Russian law, including the preparation and submission of letters rogatory requests.

To discuss your asset-tracing strategy in light of the new guidance — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• International letters rogatory directed at Russian authorities: procedural overview
• Comparative analysis of international letters rogatory frameworks in Russian enforcement proceedings
• Asset tracing in Russian insolvency: a creditor's guide

Q: What specifically changed in the Federal Bailiff Service guidance on international letters rogatory?

A: The guidance formalises the administrative requirements that letters rogatory directed at Russian enforcement authorities must meet before they are accepted for execution. The principal changes are: a mandatory certified translation of the full request — including all procedural recitals — authenticated in accordance with the applicable bilateral treaty or apostille; a formal acceptance or return notice from the receiving enforcement office within a prescribed administrative window; and strict channel requirements that reject requests submitted through the wrong diplomatic or judicial route. Prior to the guidance, these requirements were applied inconsistently at officer level. The guidance removes that discretion and makes formal compliance a threshold condition.

Q: Which foreign creditors are most directly affected, and how?

A: The guidance is most directly relevant to foreign trade creditors, institutional creditors, and distressed investors who use international letters rogatory to compel disclosure from Russian banks, registries, or state bodies as part of an asset-tracing or enforcement strategy. Creditors operating under bilateral treaty frameworks — including those from many European, CIS, and Asian jurisdictions — will find the formal requirements immediately applicable. For foreign law firms coordinating cross-border recovery strategies with a Russian component, the guidance makes pre-submission compliance review a necessary step rather than an optional one. A defective submission returned on formal grounds does not toll limitation periods under Russian civil procedure.

Q: What should a foreign creditor do if a letter rogatory is already in the Russian enforcement system?

A: Creditors whose requests were submitted before the guidance came into effect should instruct Russian counsel to enquire proactively with the relevant enforcement office to confirm whether the request has been formally accepted or placed in a pending return queue. If a return notice is received, the defects identified should be remedied as a priority, bearing in mind that any limitation period relevant to the underlying claim continues to run. Creditors preparing new requests should treat the guidance's formal checklist as a condition precedent to submission — not as guidance to be reviewed after the request is filed.

Vetrov & Partners is a Russian boutique law firm established in 2009. The firm is recognised by Pravo-300 — Russia's principal legal directory — for eight consecutive years, and is listed as a trusted adviser by the German Consulate General in Novosibirsk.

The firm's Asset Tracing & Recovery practice advises foreign creditors, institutional investors, and foreign law firms on asset-identification, preservation, and cross-border enforcement strategies under Russian law. This includes the preparation and submission of international letters rogatory requests, creditor-side representation in Russian insolvency proceedings, and coordination with counsel in CIS, EAEU, and European jurisdictions. With over 1,000 matters handled since inception, the team provides direct partner involvement on every engagement.

Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

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.

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