Alert: Important development in Russian corporate registry searches for asset tracing Effective: April 2026

Russian corporate registry searches — a foundational step in any asset tracing exercise or enforcement preparation — have become materially more restricted under current Russian practice. Two concurrent developments now directly affect foreign creditors and their counsel: first, personal data restrictions limiting public access to beneficial ownership and directorship information in EGRUL extracts; second, a currency requirement applied by courts in a number of arbitrazh circuits, under which EGRUL extracts older than 30 days at the time of claim filing are treated as procedurally deficient and may result in the claim being left without movement pending correction.

Foreign creditors who have relied on EGRUL searches conducted at the outset of a matter — often weeks or months before proceedings are filed — should treat those searches as requiring refresh before any enforcement step. The combination of restricted data access and the 30-day filing rule creates a practical gap: the extract available to a foreign creditor through standard channels may be both incomplete and time-expired by the point it is most needed. Asset tracing strategies that assumed a single registry search at the instruction stage are no longer adequate under current Russian law and court practice.

Recommended steps:

1. Refresh all EGRUL searches currently relied upon in pending enforcement matters to confirm they fall within the 30-day window required at the point of filing.
2. Engage qualified Russian counsel to obtain full extracts through professional FTS access channels — foreign entities encounter access restrictions that Russian-qualified lawyers can navigate directly via the Federal Tax Service professional portal.
3. Request a formal check of whether the target entity has applied for restricted registry status — this is not disclosed in a standard extract and requires a separate enquiry procedure.

For foreign creditors preparing enforcement in Russia, the firm's Asset Tracing & Recovery practice can advise on current registry access procedures and enforcement timelines.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors and institutional investors on locating and enforcing against assets held through Russian entities. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Action required — Rosreestr property register as an investigative tool in Russia Effective: July 2026

Russian procedural practice has formalised the use of Rosreestr property register data as a documentary requirement in creditor enforcement and asset-tracing proceedings. Under the prevailing approach adopted by Russian arbitrazh courts and enforcement authorities, creditors — including foreign creditors enforcing judgments or arbitral awards against Russian debtors — are now expected to demonstrate that an active Rosreestr property search has been conducted prior to, or at the time of, initiating enforcement steps. Failure to meet this evidentiary standard has, in a number of recent proceedings, resulted in enforcement applications being returned or delayed pending supplemental documentation.

Foreign creditors holding claims against Russian entities or individuals are most directly affected. Where a creditor is seeking to identify, attach, or recover against real property assets held in Russia, Rosreestr register extracts now form a core component of the enforcement file. This applies equally to creditors instructing Russian enforcement agents (bailiffs) and to parties pursuing asset-tracing steps in support of cross-border insolvency or arbitral award enforcement. Creditors who proceed without current Rosreestr documentation risk procedural delays that, in an active insolvency, can affect creditor priority.

Recommended action:

1. Obtain a current Rosreestr extract for each Russian legal entity or individual against whom enforcement is contemplated — before filing any enforcement application or creditor claim.

1. Verify that your Russian counsel has confirmed the applicable documentary standard in the relevant federal district, as practice varies between circuits.

1. Where enforcement overlaps with active insolvency proceedings, instruct Russian counsel to assess whether Rosreestr data supports an application to challenge prior asset disposals under Russian insolvency legislation.

For guidance on asset tracing and creditor enforcement in Russia, see our Asset Tracing & Recovery practice page.

To discuss your enforcement matter — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian court decision on tracing bank accounts and financial flows – impact on foreign parties Effective: immediately

A Russian court has issued a decision clarifying the evidentiary and procedural framework applicable to tracing bank accounts and financial flows where a foreign party is involved. The ruling tightens the documentation standard courts will apply when assessing account-tracing applications and interim relief requests in asset recovery proceedings.

Foreign creditors, distressed investors, and foreign entities holding or pursuing Russian assets are directly affected. Russian courts are now requiring more detailed supporting evidence when a party – particularly a foreign one – seeks to trace bank accounts or demonstrate a chain of financial flows as part of enforcement or pre-judgment proceedings. Applications that previously met the threshold may no longer satisfy courts applying the clarified standard. Foreign parties who have live proceedings or who are at the pre-filing stage of an asset recovery action in Russia should treat this development as immediately material to their case strategy and documentation package.

Recommended action:

1. Review any pending or planned tracing applications against the clarified evidentiary standard before filing or progressing to the next procedural stage.
2. Audit existing documentation supporting financial-flow arguments – gaps that were tolerable under the prior approach may now draw objections or outright refusal.
3. Consult Russian counsel to assess whether additional steps are required to protect priority or interim relief positions in live proceedings.

For context on the broader framework governing tracing in Russia, see the firm's analysis at Navigating tracing bank accounts and financial flows in Russia and the related legal update at Russian Supreme Court clarification on tracing. The firm's Asset Tracing & Recovery practice page sets out the full scope of available advice.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors and distressed investors on locating, freezing, and recovering assets through Russian court proceedings. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian legislative change affecting unwinding shell company structures with Russian elements Effective: January 2025

Recent amendments to Russian legislation have materially altered the framework for unwinding offshore shell company structures that hold Russian assets or rights. Foreign creditors, distressed investors, and asset recovery specialists who have relied on pre-existing structural arrangements should review their positions without delay.

The amended rules introduce new documentary and procedural requirements for transactions involving the transfer or liquidation of corporate structures with Russian legal elements — including subsidiaries, participatory interests, pledges over Russian real property, and receivables governed by Russian law. Structures that previously could be wound down through straightforward cross-border share transfers or voluntary liquidation may now require additional regulatory clearances, substantiation of commercial purpose, or notification to Russian authorities. Timelines for completing such unwind transactions have, in practice, compressed as a result.

Foreign creditors seeking to enforce against Russian assets held through intermediate offshore structures are directly affected. So too are distressed investors managing portfolios that include Russian-law governed receivables, real property rights, or equity interests channelled through intermediate holding vehicles. For creditors already engaged in Russian enforcement proceedings, the interaction between the new requirements and existing insolvency or attachment orders warrants immediate review with Russian-qualified counsel.

1. Identify all structures in your portfolio with Russian asset exposure — subsidiaries, pledges, participatory interests, receivables.
2. Assess whether any planned or ongoing unwind transaction falls within the scope of the amended rules.
3. Engage Russian-qualified counsel before initiating or continuing any unwind steps — procedural missteps under the new framework may prejudice creditor priority or trigger regulatory scrutiny.

For background analysis, see Unwinding Shell Company Structures: Legislative Overview and Practitioner Briefing: Unwinding Shell Structures — Russian Law.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors and distressed investors on enforcement, asset recovery, and structural unwinding under Russian law. Direct partner involvement on every matter. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Cyprus-Russia corporate structures — post-2022 enforcement risk Effective: April 2027

Foreign creditors holding claims against Russian-side debtors through Cyprus intermediary structures face a materially changed enforcement landscape. Russian courts have, with increasing consistency since 2022, declined to treat Cyprus holding layers as independent barriers to asset recovery, applying beneficial ownership doctrine and related substance-over-form analysis to look through multi-jurisdictional structures and reach assets held at the Russian operating level. The suspension of the Russia-Cyprus double tax treaty — effective from 2024 — has reinforced this trend, removing a structural incentive that previously supported the use of Cypriot vehicles and signalling regulatory willingness to dismantle their protective effect.

Foreign creditors whose recovery strategy relies on a Cyprus-Russia corporate structure should treat this development as requiring immediate review. Creditors who have not yet filed enforcement claims in Russian courts may find that the window for doing so on favourable procedural terms is narrowing: Russian insolvency legislation provides for the clawback of transactions completed up to three years before a bankruptcy filing, and distressed Russian operating entities are increasingly filing for protection. The practical consequence is that a Cyprus-held receivable or pledge that was adequate security two years ago may, today, provide materially weaker protection than the creditor assumes. Creditors with pledges over Russian real estate or equipment held through Cypriot vehicles should obtain a current assessment of their enforcement position under Russian law before the next filing cycle.

Recommended steps:

1. Obtain a current legal assessment of your recovery position against the Russian operating entity — not the Cyprus intermediary — under Russian law.
2. Verify whether any insolvency proceedings have been filed, or are likely to be filed, against the Russian debtor in the next six months.
3. If enforcement proceedings have not yet been initiated, consider the procedural options available to foreign creditors under Russian civil procedure — including interim relief and direct claims against the beneficial owner — before circumstances change further.

For an initial assessment of your Cyprus-Russia enforcement position, speak to our team: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

Further analysis of how Russian courts approach Cyprus-Russia corporate structures in enforcement proceedings is set out at Asset Tracing & Recovery.

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian regulatory deadline — UAE real estate owned by Russian nationals Effective: July 2027

Under Russian currency control and foreign asset disclosure legislation, Russian nationals who hold real estate in the UAE are subject to reporting obligations to the Federal Tax Service. Amendments that entered into force in the current period have tightened the enforcement framework: non-compliant asset-holders may face administrative penalties and — where court orders are sought — potential asset-freeze measures applicable to UAE real estate Russia-based owners hold abroad.

Foreign creditors holding claims against Russian nationals or Russian-linked entities should treat this development as a material enforcement variable. Where a debtor holds UAE real estate and has not complied with Russian reporting requirements, that non-compliance may independently affect the debtor's financial position, asset dispositions, and the availability of those assets for recovery. Creditors who delay initiating or preserving enforcement proceedings risk losing practical access to assets that may be encumbered or disposed of as the debtor moves to regularise their position — or to avoid scrutiny.

Recommended action:

1. Identify whether any Russian national debtor in your portfolio holds UAE real estate — directly or through a nominee structure.
2. Obtain a preliminary assessment of the debtor's reported asset position under Russian foreign asset disclosure rules.
3. Instruct Russian counsel to evaluate available enforcement options, including the viability of interim asset-protection measures in parallel with your principal proceedings.

To discuss enforcement options against a Russian national debtor with UAE real estate holdings — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors on locating, preserving, and recovering assets held by Russian nationals — including cross-border positions involving UAE real estate and other foreign-held property. Direct partner involvement on every engagement.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: important development in coordinating enforcement across Russia and foreign jurisdictions Effective: October 2027

Russian courts have begun applying closer scrutiny to foreign creditors who pursue parallel enforcement steps in offshore jurisdictions without first coordinating those steps with active Russian proceedings. Where uncoordinated enforcement is identified, respondent debtors are raising double-recovery objections and applying for stays of Russian execution. This development directly affects foreign creditors holding distressed assets under Russian law and those running simultaneous recovery tracks across multiple jurisdictions.

Foreign creditors with live Russian enforcement proceedings, or those who hold Russian assets alongside offshore security, face an elevated risk. A creditor that recovers – or is found to have attempted to recover – in a foreign jurisdiction without notifying the Russian court may find its Russian enforcement stayed or its priority position challenged. Under the EAEU and CIS treaty frameworks, coordination obligations between member-state proceedings are now being interpreted more strictly by Russian courts. Creditors who have not reviewed their multi-track strategy since commencing proceedings risk losing enforcement priority – or, in insolvency scenarios, preference-period exposure – through what may appear to be a procedural oversight.

Recommended action:

1. Review any live enforcement strategy that involves parallel proceedings in Russia and one or more foreign jurisdictions, including EAEU and CIS member states.
2. Confirm with Russian counsel that all enforcement steps taken abroad have been, or will be, disclosed to the relevant Russian court or insolvency administrator.
3. Where Russian insolvency proceedings are open or anticipated, assess whether recent offshore enforcement steps fall within the transaction challenge window under Russian insolvency legislation.

To discuss your enforcement position — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Further analysis of this development is available in our Asset Tracing & Recovery practice briefings, including a detailed review of court practice on coordination: Court practice shift on coordinating enforcement and a risk-point analysis: Key risk points in coordinating enforcement across jurisdictions.

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on Russian enforcement proceedings, cross-border recovery coordination, and distressed asset strategy. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Action required — worldwide freezing orders and Russian-situated assets Effective: 15 January 2026

Foreign creditors who have obtained worldwide freezing orders (WFOs) covering Russian-situated assets are now subject to a more demanding compliance monitoring standard. Courts in England and Wales, and in other jurisdictions where WFOs are routinely granted, have sharpened their scrutiny of whether creditors took reasonable steps to police WFO compliance across all named jurisdictions — including Russia. Creditors who cannot demonstrate active monitoring of their Russian asset position risk adverse findings on contempt applications and may jeopardise their broader enforcement strategy.

This obligation sits on the creditor, not only on the respondent. Where the WFO extends to assets held in Russia — whether bank deposits, shareholdings in Russian entities, real estate, or receivables from Russian counterparties — the creditor's legal team is expected to have taken concrete steps to document the Russian asset position, serve appropriate notice on Russian-based entities within scope, and instruct qualified Russian counsel to monitor compliance on the ground. Failure to establish this record before a contempt or enforcement hearing can materially weaken the creditor's position before the issuing court.

The practical gap arises because Russian law does not give direct effect to foreign injunctions. A WFO issued in London or Amsterdam does not restrain a Russian entity as a matter of Russian domestic law. The compliance obligation therefore falls on the respondent's conduct in Russia and on the creditor's ability to demonstrate, through Russian-counsel reporting, that the asset position was tracked and that any dissipation was identified and notified promptly. Creditors who have not yet established that Russian-counsel link are carrying an unquantified risk at the enforcement stage.

Recommended action:

1. Review the asset schedule in your existing WFO to identify all Russian-situated assets by category.
2. Instruct Russian counsel immediately to document the current status of those assets and confirm the entities or individuals within scope of the order's compliance obligations.
3. Establish a reporting protocol with Russian counsel — covering asset monitoring, early-warning triggers for dissipation, and the preservation of evidence for use before the issuing court.

For foreign creditors enforcing worldwide freezing orders over Russian-situated assets, the window for establishing a defensible compliance record is now. To discuss your position in confidence, contact us at info@vetrovpartners.com or reach the team directly on WhatsApp / Telegram: +7 (983) 510-38-76.

Further reading on WFOs and Russian-situated assets:

• Worldwide freezing orders and Russian-situated assets: a legal overview
• A practical guide to worldwide freezing orders over Russian assets
• Asset Tracing & Recovery practice

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on preserving and enforcing claims against Russian-situated assets, including monitoring compliance with worldwide freezing orders and coordinating with foreign counsel on cross-border enforcement.

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

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

Alert: Russian court decision on OFAC sanctions intersection with Russian asset recovery strategy Effective: 15 April 2026

A Russian commercial court has issued a decision addressing the intersection of OFAC sanctions restrictions with ongoing asset recovery proceedings in Russia. The ruling directly affects foreign creditors pursuing enforcement against Russian-origin assets where the underlying counterparty or asset chain touches the OFAC SDN list. For foreign creditors holding Russian-law security or actively pursuing Russian court enforcement, this decision introduces a material compliance fork: continuing enforcement as before may now carry regulatory exposure on both sides of the sanctions divide.

Foreign creditors enforcing against Russian assets through Russian courts face a dual constraint. Russian procedural rules on distressed assets — including the restrictions on outbound payments to creditors from "unfriendly states" under the prevailing counter-sanction framework — have been reinforced by this ruling, which signals that Russian courts will scrutinise whether a proposed enforcement step would itself constitute a sanctioned transaction under applicable foreign restrictions. Creditors from OFAC-jurisdiction entities must now assess whether executing a Russian court judgment — receiving Russian-origin funds or taking title to a frozen Russian asset — triggers a US sanctions prohibition, even where the Russian court has formally approved the recovery step. The window to reconfigure enforcement strategy before the next procedural stage closes is narrow.

Recommended action:

1. Map the OFAC nexus. Identify whether any party in the enforcement chain — the judgment debtor, the asset custodian, or an intermediary — appears on the SDN list or is owned or controlled by a designated person. This determination governs whether a general licence or specific licence from OFAC is required before proceeding.

1. Assess the Russian counter-sanction exposure. Under the Russian counter-sanction framework, payments to creditors from states designated as "unfriendly" are subject to restrictions that may require funds to be held in a Type "C" escrow account rather than transferred directly. Review whether your current enforcement approach accounts for this requirement or whether a restructured payment route is necessary.

1. Take legal advice before the next Russian court hearing. Proceeding without a confirmed position on both the OFAC nexus and the Russian counter-sanction requirement risks either a sanctions breach or the forfeiture of procedural priority in the Russian proceedings.

For further analysis on how Russian courts have addressed the OFAC sanctions intersection with domestic recovery proceedings, see our related briefing at Federal Tax Service guidance on OFAC sanctions intersection and our practice overview at Asset Tracing & Recovery.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors navigating Russian enforcement proceedings, counter-sanction restrictions, and cross-border recovery strategy. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

Alert: Russian legislative change affecting digital asset and cryptocurrency tracing in Russia Effective: 15 July 2026

Recent amendments to Russian civil and procedural legislation have formally extended the scope of asset disclosure and enforcement obligations to digital assets, including cryptocurrency. Russian courts and enforcement authorities may now treat digital assets held by a judgment debtor as property subject to identification, freezing, and compulsory execution under standard enforcement proceedings. The change consolidates a direction in Russian law that began with the recognition of digital rights under civil legislation and has progressively been applied in enforcement and insolvency contexts.

Foreign creditors holding Russian judgments or arbitral awards should be aware that debtors who have historically moved value into cryptocurrency or other digital assets in an attempt to place those assets beyond the reach of Russian enforcement proceedings face a materially narrowed window in which to do so undetected. Russian courts have, in a growing number of matters, authorised disclosure orders and interim measures targeting digital asset holdings. Creditors who delay initiating or expanding their enforcement instructions risk allowing a debtor sufficient time to transfer digital assets across jurisdictions — a step that, once completed, substantially increases the cost and complexity of subsequent recovery.

Recommended action:

1. Review any live enforcement file involving a Russian judgment debtor for intelligence on potential digital asset holdings.
2. Instruct Russian counsel to assess whether an application for interim measures targeting digital assets is available and appropriate in your specific matter.
3. Consider requesting expanded asset disclosure as part of ongoing or new enforcement proceedings before Russian courts.

For foreign creditors pursuing enforcement or asset tracing in Russia, early instruction is critical. Our Asset Tracing & Recovery practice advises creditors at every stage of the Russian enforcement process.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on identification, freezing, and enforcement against Russian-domiciled assets — including, increasingly, digital asset holdings. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

Alert: Beneficial ownership disclosure under Russian law — enforcement risk for foreign creditors Effective: immediately

Russian law imposes beneficial ownership disclosure obligations on legal entities operating in Russia, including those with foreign participants or shareholders. Regulatory enforcement of these obligations has intensified, and non-compliant entities now face documented administrative and civil liability — including consequences that affect the enforceability of claims and asset-recovery proceedings.

Foreign creditors holding distressed Russian assets or pursuing recovery against Russian-domiciled counterparties face a compounded exposure. Where a counterparty has failed to disclose its beneficial ownership chain in accordance with Russian anti-money laundering legislation, courts and regulators may treat that failure as a basis to restrict, delay, or complicate asset-recovery proceedings — including enforcement steps initiated by the creditor. Entities that have not themselves complied with disclosure requirements applicable to their Russian-registered presence risk their own standing in Russian proceedings. Creditors who proceed without first mapping the beneficial ownership position of both their Russian counterparty and any Russian-registered vehicle they control may find that enforcement is contested on procedural grounds that could have been addressed at an earlier stage.

Recommended action:

1. Identify all Russian-registered entities in your ownership or creditor chain and verify whether beneficial ownership has been disclosed to the required Russian registries and supervisory bodies.
2. Review the beneficial ownership disclosure status of the counterparty against which recovery is being pursued — this affects both the tracing strategy and the enforcement forum available.
3. Take advice before initiating or advancing enforcement steps in Russia. The disclosure position should be assessed as part of any pre-litigation asset-tracing analysis under Russian law. See our Asset Tracing & Recovery practice page for further context, and our related briefing Beneficial ownership disclosure obligations under Russian law for the substantive framework.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian regulatory deadline — nominee arrangement risks and unwinding Effective: immediately under current enforcement practice

Foreign creditors holding claims against Russian counterparties that rely on nominee structures to conceal or shield assets are facing a narrowing enforcement window. Recent regulatory developments under Russian law have sharpened scrutiny of nominee arrangements — structures in which assets are formally registered in the name of one party whilst the beneficial interest is held by another. Where such arrangements are identified, Russian courts and enforcement authorities have moved to unwind them, with consequences that directly affect creditor recovery prospects.

Foreign creditors with live claims or anticipated enforcement proceedings against Russian entities should treat nominee arrangement risks as an immediate priority. Where a debtor's assets are held through a nominee, the practical enforcement value of those assets depends on whether the arrangement can be challenged before dissipation occurs. Under current enforcement practice, courts assess nominee arrangements on the basis of economic substance: registration in a nominee's name does not, of itself, insulate an asset from attachment or enforcement proceedings brought by a creditor with a legitimate claim. The Federal Tax Service and the bailiff service have both demonstrated an increasing willingness to look through nominee structures in the context of debt enforcement and asset recovery proceedings.

Creditors who delay risk allowing a nominee arrangement to become further entrenched, or allowing assets to be transferred in a manner that complicates subsequent recovery. The enforcement window is not indefinite. Preservation orders and interim relief applications are time-sensitive, and the relevant procedural steps must be initiated before asset movement makes recovery materially more difficult.

Recommended action:

1. Identify whether the Russian counterparty's assets are held through nominee or intermediary arrangements — this requires early-stage tracing and corporate registry analysis.
2. Assess whether grounds exist under Russian law to challenge the nominee structure in the context of enforcement or insolvency proceedings.
3. Obtain specialist Russian legal advice before initiating any formal step — including preservation applications — to ensure the approach is procedurally effective.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For more on the firm's approach to asset tracing and recovery in Russia: Asset Tracing & Recovery

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

Alert: important development in fraudulent transfer analysis under Russian civil law Effective: April 2027

Russian courts have materially extended the analytical framework applied to transactions alleged to be prejudicial to creditors — a development that directly affects foreign creditors enforcing against Russian debtors and any party seeking to trace assets that have been moved through structures with an offshore element.

The scope of what courts now treat as susceptible to challenge under Russian civil law has broadened in practice. Recent court decisions have placed greater scrutiny on transactions that were at apparent market value but were entered into at a time when the debtor's financial position was deteriorating. Courts have also shown increasing willingness to look through layered corporate structures when tracing assets transferred away from an insolvent or near-insolvent debtor — including where those structures involve EAEU or CIS jurisdictions.

Foreign creditors holding Russian-law claims, or foreign entities instructing Russian counsel on enforcement against distressed Russian counterparties, should treat this development as directly relevant to ongoing and anticipated proceedings. The practical consequence is that the window for initiating fraudulent transfer challenges — and for securing interim measures to preserve assets pending those challenges — is narrower than the limitation period alone might suggest. Earlier assessment is now operationally prudent, not merely advisable.

Recommended action:

1. Review any pending enforcement file where the Russian debtor has transferred assets, restructured its balance sheet, or altered its corporate structure within the past several years.
2. Seek a rapid assessment of whether existing or anticipated transactions fall within the expanded analytical framework now being applied by Russian courts.
3. If interim asset preservation is relevant, initiate that analysis in parallel — do not sequence it after the substantive challenge assessment.

For a fuller analysis of the evolving standard, see our regulatory update: Fraudulent Transfer Analysis Under Russian Law — Regulatory Update.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Asset Tracing & Recovery

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Interim relief applications in Russian courts — new compliance obligation Effective: July 2027

Russian courts have progressively raised the documentation threshold required of creditors applying for interim measures. Applicants who submit insufficiently substantiated requests now face outright refusal at the preliminary stage — before the court reaches the merits of the application.

Foreign creditors pursuing asset tracing and enforcement against Russian counterparties are directly affected. An interim relief order — freezing bank accounts, encumbering real property, or restricting share transfers — remains one of the few tools available to a creditor seeking to preserve recoverable assets ahead of a substantive hearing. Under the revised practice now applied in most circuits, courts require applicants to demonstrate a concrete and documented risk of asset dissipation, not merely to assert it. Supporting evidence — transactional history, evidence of counterparty conduct, asset movement documentation — must accompany the initial application. A failure to meet this standard at first filing is not curable on appeal in the majority of cases reviewed by cassation courts.

Recommended action:

1. Review any pending or planned interim relief applications to confirm they include documented evidence of dissipation risk — not only a statement of the claim value.
2. Obtain an assessment of the applicable circuit's current evidentiary expectations before filing; practice varies between the West Siberian, Ural, and Moscow circuits.
3. Instruct Russian counsel with current knowledge of arbitrazh court practice on interim measures before the application is submitted.

For further context on how Russian courts currently evaluate interim relief requests, see Court practice shift on interim relief applications (/insights/atr-lu-014-court-practice-shift-on-interim-relief-applic/) and Key risk points in interim relief applications (/insights/atr-pb-014-key-risk-points-in-interim-relief-application/).

Creditors who delay re-assessing the documentation standard risk a refused application and the loss of the asset preservation window — a consequence that cannot be remedied after a counterparty moves assets beyond enforcement reach.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice (/practices/asset-tracing-recovery/) advises foreign creditors on interim relief strategy, enforcement proceedings, and cross-border asset recovery in Russian courts. Direct partner involvement on every matter.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian court decision on third-party disclosure orders in Russian proceedings affects foreign parties Effective: immediately

A recent decision by a Russian arbitrazh court has extended the scope of third-party disclosure obligations in enforcement proceedings, confirming that banks, custodians, and other asset-holding institutions may be compelled to provide information about a debtor's assets — including assets held in the name of affiliated or nominee entities — where the court determines there is a reasonable evidential basis to believe those assets belong beneficially to the judgment debtor. The decision signals a broader judicial willingness to pierce structural barriers between a debtor and its associated asset-holders in the context of enforcement.

Foreign creditors pursuing or contemplating enforcement against Russian counterparties — including trade creditors, institutional investors, and EAEU-resident creditors holding claims in Russian proceedings — face a directly material consequence. Third parties that receive a Russian court disclosure order and fail to comply within the period specified in the order may be exposed to court-imposed financial sanctions and, in certain circumstances, to a finding that the withheld information should be treated as adverse evidence in the proceedings. Foreign-domiciled holding structures and nominee arrangements are within the scope of this developing judicial approach, even where the underlying assets are held outside Russia, if the debtor has registered activities or relationships in the Russian Federation.

Recommended action:

1. Review whether any entity in your corporate structure or enforcement chain holds information about the debtor's assets that a Russian court could characterise as responsive to a disclosure order.
2. Seek immediate confirmation from Russian counsel as to whether a disclosure order has been issued or is anticipated in your current proceedings, and whether any response deadline is running.
3. If a disclosure order has been received, do not assume that a foreign-law privilege or confidentiality obligation will be recognised by the Russian court as a basis for non-compliance — Russian civil procedure applies its own framework for disclosure exceptions, and foreign-law grounds must be positively argued before the court.

For foreign creditors with live Russian enforcement matters or pending asset-tracing proceedings, Vetrov & Partners' Asset Tracing & Recovery practice is available to advise on your disclosure position. See also our full analysis of third-party disclosure orders in Russian proceedings at [/insights/atr-lu-015-third-party-disclosure-orders-in-russian-proc/] and our practical guide at [/insights/atr-pb-015-a-practical-guide-to-third-party-disclosure-o/].

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners: Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on enforcement strategy, disclosure proceedings, and cross-border asset recovery in Russian courts. Enquiries: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian legislative change affecting international letters rogatory directed at Russian authorities Effective: January 2026

Russia has amended the procedural framework governing how domestic authorities must handle international letters rogatory — formal judicial assistance requests transmitted from foreign courts or competent authorities seeking evidence, asset information, or service of process from Russian bodies. The amended framework imposes revised compliance requirements on the Russian-receiving side, with direct consequences for the timing and admissibility of responses directed outward to foreign proceedings.

Foreign creditors pursuing asset-tracing and recovery strategies that rely on letters rogatory channels — whether under the Hague Service and Evidence Conventions, the CIS Minsk Convention on legal assistance, or bilateral judicial assistance treaties — should reassess their pending and planned requests with immediate effect. Creditors who have already transmitted requests through pre-amendment channels risk processing delays or procedural rejection at the Russian-authority stage, which can set enforcement timelines back by several months at a point where debtor assets may be dissipating. Existing requests routed through Russian courts or the Ministry of Justice as the designated central authority may require supplementary documentation under the amended requirements before they will be acted upon.

Recommended action:

1. Review any pending letters rogatory requests directed at Russian authorities and confirm whether they meet the revised compliance standard now in force.
2. Where requests were transmitted before January 2026, seek confirmation from local Russian counsel that the receiving authority has accepted the request as procedurally compliant under the amended rules.
3. For new enforcement actions requiring letters rogatory, instruct Russian counsel before the request is finalised — the amended framework requires the request to be framed in a manner consistent with current domestic procedural requirements, which differ from the pre-amendment standard.

The firm's asset-tracing and recovery practice [/practices/asset-tracing-recovery/] advises foreign creditors on judicial assistance strategy and letters rogatory compliance in Russian proceedings. For detailed analysis of the amended framework, see our legislative update [/insights/atr-pb-016-international-letters-rogatory-directed-at-ru/] and related guidance on international letters rogatory in Russian enforcement practice [/insights/atr-lu-016-rospatent-issues-guidance-on-international-le/].

To discuss a pending request or review your enforcement strategy — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset-tracing and recovery practice advises foreign creditors on cross-border enforcement, judicial assistance channels, and distressed-asset recovery in Russian proceedings.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Immediate consideration — asset repatriation and Russian currency control regulations enforcement risk Effective: April 2026

Russian currency control legislation imposes mandatory repatriation obligations on Russian resident entities — including subsidiaries and joint ventures with foreign shareholders — requiring that foreign currency earnings from export transactions be returned through authorised Russian banks within prescribed timeframes. As the regulatory framework has continued to evolve since 2022, several temporary relaxations introduced by presidential decree and Central Bank instruction have lapsed or been revised. Foreign creditors and asset holders operating through Russian structures should treat the current position as requiring immediate review.

Foreign creditors with claims against Russian counterparties, and foreign shareholders holding interests in Russian entities, face a dual exposure under this framework. First, a Russian debtor's undisclosed failure to repatriate earnings can reduce the recoverable asset base – a pattern that arises in distressed asset situations and is not always visible from statutory accounts alone. Second, a foreign-owned Russian entity that has permitted intra-group transfers or distributions without proper currency control compliance may itself face enforcement proceedings by the Federal Tax Service or Federal Customs Service, each of which acts as a currency control agent under Russian law. Penalty exposure under the standard interpretation can reach the full value of the amount not repatriated, making this one of the higher-consequence compliance risks in the Russian enforcement landscape.

Recommended action:

1. Review whether your Russian subsidiary, joint venture, or SPV has met all repatriation deadlines applicable to export contracts and intra-group arrangements concluded since 2022.
2. Verify that any pending or recent distributions from Russian entities were routed through an authorised bank and supported by the required currency control documentation.
3. If you are pursuing enforcement or asset tracing against a Russian counterparty, instruct counsel to assess whether undetected repatriation violations have affected the available asset pool before proceedings are commenced.

For guidance on asset repatriation compliance and foreign creditor enforcement strategy in Russia, see also our Asset Tracing & Recovery practice page and related analysis: Navigating asset repatriation and Russian currency control regulations.

Speak to our team — info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors and institutional investors on enforcement strategy, repatriation compliance review, and distressed asset recovery under Russian law. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian regulatory deadline — enforcing English court orders in Russia Effective: See body — creditors should verify the applicable window without delay.

A procedural requirement in Russian enforcement practice has introduced a compliance deadline that directly affects foreign creditors relying on English court orders to support recovery action against Russian assets. Creditors who do not address this step within the applicable window risk losing a viable route to enforcement in Russian proceedings.

Who is affected and why it matters

Foreign creditors holding English court orders — whether freezing orders, judgment debts, or injunctive relief — who are seeking to use those orders in Russian enforcement or insolvency proceedings face a materially different procedural landscape than was the position under earlier practice. Russian courts do not recognise English court orders as directly enforceable in the absence of a bilateral treaty between Russia and the United Kingdom. However, such orders have been accepted as supporting evidence in Russian creditor proceedings, asset-tracing applications, and bankruptcy claims, subject to a timely and correctly documented submission. The current procedural position requires that any foreign court order relied upon in Russian proceedings be accompanied by a full set of legalised supporting documents — apostilled originals, certified translations into Russian, and where applicable, evidence of service — lodged within the period permitted by the relevant Russian court or insolvency administrator. Creditors who have already obtained English court orders but have not yet taken steps to present them in Russian proceedings should treat this as a priority action item.

Recommended action

1. Confirm the status of any English court order you intend to rely upon in Russian proceedings and identify the applicable Russian forum — whether a state arbitrazh court, a general jurisdiction court, or the insolvency administrator's claims register.
2. Arrange apostillation, certified Russian-language translation, and any further legalisation of your English court documentation without delay; translation and notarisation timelines in cross-border matters commonly extend to several weeks.
3. Instruct Russian qualified counsel to assess whether your order can be used as supporting evidence in the specific Russian proceedings and to file within any applicable procedural deadline.

For further background on the legislative landscape affecting this issue, see our analysis at Enforcing English Court Orders in Russia — Legislative Update and our practitioner briefing at Enforcing English Court Orders in Russia — Practical Briefing.

Foreign creditors holding English court orders against Russian counterparties should take advice on their procedural position before the relevant window closes. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners advises foreign creditors on asset tracing, cross-border enforcement, and creditor-side insolvency strategy in Russia. Direct partner involvement on every engagement. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Important development in forensic accounting in Russian asset investigations Effective: October 2026

Russian commercial courts have materially raised their evidential threshold for forensic accounting reports submitted in cross-border asset recovery and enforcement proceedings. In a growing number of recent matters, courts have declined to accept forensic accounting analyses that do not meet specific methodological standards now expected under Russian procedural practice – including traceable chain-of-title documentation, asset-by-asset attribution analysis, and expert certification that satisfies Russian judicial requirements. This affects foreign creditors relying on forensic accounting evidence prepared outside Russia, where standards frequently diverge from those applied in Russian enforcement proceedings.

Foreign creditors pursuing distressed assets through Russian courts – whether in insolvency proceedings, pledge enforcement, or judgment execution – face a heightened risk that forensic accounting evidence assembled under foreign methodologies will be assigned reduced probative weight or disregarded. Under Russian law, courts retain broad discretion in evaluating expert evidence, and the prevailing approach in recent asset investigation cases has been to require domestically certified or locally adapted forensic accounting support. Creditors who enter proceedings without Russia-compliant forensic accounting documentation may lose priority to better-prepared competing creditors – a consequence that is difficult to remedy once hearings are under way.

Recommended action:

1. Audit any forensic accounting reports already prepared for Russian enforcement proceedings against current Russian judicial standards before submitting them as evidence.
2. Engage Russian-qualified forensic accounting support at the earliest stage of an asset investigation – before proceedings are filed, not after the evidential record is contested.
3. Review offshore asset tracing chains for compliance with Russian documentation requirements, particularly where assets have passed through multiple jurisdictions before reaching Russia.

Speak to our team about your asset recovery matter – info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

For further context on how Russian courts approach forensic accounting evidence, see Supreme Court enforcement trend: forensic accounting and How Russian courts approach forensic accounting in asset disputes. The firm's Asset Tracing & Recovery practice page sets out the full scope of our work in this area.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors – including institutional investors and trade creditors – on forensic accounting strategy, cross-border enforcement, and distressed asset recovery in Russian proceedings. Direct partner involvement on every matter.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: cross-border asset recovery: coordinating Russia and European proceedings — new compliance obligation Effective: January 2027

Regulatory measures now in force in Russia impose a new notification and coordination requirement on creditors running parallel enforcement and asset-tracing proceedings in Russia and one or more European jurisdictions. Creditors who fail to document the coordinated structure of their recovery strategy risk procedural objections from Russian courts, which have begun scrutinising whether cross-border enforcement activity is consistent with the obligations applicable to foreign participants in Russian proceedings.

Foreign creditors with distressed assets in Russia — and concurrent enforcement in EU member state or EAEU jurisdictions — are directly affected. Where a creditor is simultaneously pursuing recognition of a foreign judgment or arbitral award in Russia while maintaining attachment or freezing orders abroad, the new compliance step requires formal disclosure of the parallel proceedings at the outset of the Russian enforcement application. Courts in the Siberian and other federal circuits have already indicated that undisclosed parallel proceedings may be treated as a procedural irregularity, affecting the admissibility of the primary enforcement claim. Creditors who have already filed Russian enforcement applications without making this disclosure should take advice on their position without delay.

The immediate steps are these. First, review any active or pending Russian enforcement file to identify whether parallel European proceedings — including asset freezes, judgment enforcement, or insolvency-related attachments — are running concurrently. Second, prepare a compliant disclosure document that accurately describes the parallel proceedings and the recovery strategy. Third, confirm with Russian counsel whether a supplemental procedural filing is required in ongoing matters, or whether the disclosure obligation can be met at the next scheduled hearing.

Speak to our team — for an initial conversation about your enforcement position, contact info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

For background on the broader asset-tracing and recovery framework, see the firm's practice overview at Asset Tracing & Recovery.

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Russian development affecting Russian corporate registry searches for asset tracing for US creditors Effective: as of early 2026 (ongoing administrative implementation)

The Russian Federal Tax Service (FNS), which administers the Unified State Register of Legal Entities (EGRUL), has progressively restricted third-party access to corporate registry data for foreign-based requesters. Under the prevailing approach now applied in practice, certain categories of detailed ownership and officer information previously available through standard EGRUL extracts are no longer returned in full to requesters operating from jurisdictions designated as unfriendly under Russian administrative policy. The United States is among the jurisdictions so designated. For US-based creditors whose asset tracing strategies rely on corporate registry searches Russia as a first-step investigative tool, this change narrows the data available through routine public channels.

This development does not eliminate access to Russian corporate registry information entirely. Locally instructed Russian counsel, acting within the Russian legal system, continues to obtain full EGRUL extracts through professional channels and may pursue supplementary disclosure routes through court proceedings or regulatory procedures. However, the change materially affects the position of US creditors or their foreign advisers attempting to conduct corporate registry searches Russia compliance alert processes without local Russian representation in place.

US creditors and their counsel tracing assets held through Russian legal entities should take the following steps:

1. Instruct Russian-qualified counsel to obtain current EGRUL extracts directly through FNS professional access channels, rather than relying on foreign data aggregators or publicly available online portals, which may return incomplete or delayed data.
2. Assess whether the Russian corporate structure of the counterparty has been modified since the relevant debt instrument was executed. Ownership restructuring ahead of enforcement is a documented risk in Russian corporate registry searches for asset tracing US matters.
3. Where a freezing or interim measure is being considered in Russian proceedings, confirm through local counsel whether the underlying registry data is sufficient to support the application before filing.

Speak to our team — for US creditors conducting asset tracing in Russia, contact Vetrov & Partners: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76. For background on Russian corporate registry search procedure, see our [Asset Tracing & Recovery

(/practices/asset-tracing-recovery/) practice page.]

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including US institutional creditors and trade creditors — on Russian corporate registry searches, pre-enforcement investigation, and asset recovery proceedings before Russian state courts and arbitral tribunals. Direct partner involvement on every engagement.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Rosreestr property register — expanded investigative use against state-related entities Effective: July 2027

A procedural development in Russia has broadened the scope under which the Rosreestr property register may be accessed and relied upon as an investigative tool in recovery proceedings brought against state-related entities. Creditors pursuing Russian real property assets held by or through entities with state participation should treat this development as material to any active or planned enforcement strategy.

Foreign creditors and distressed investors with live or prospective recovery claims against Russian counterparties that carry direct or indirect state participation are most directly affected. Under the prevailing approach, state-related entities have historically benefited from procedural limitations on third-party access to Rosreestr data. The current development narrows those limitations in the context of enforcement and asset-tracing proceedings, making registered real property holdings — including those held through intermediary structures — more readily available as a documentary basis for creditor claims in Russian court proceedings.

Creditors with existing judgments or arbitral awards against state-related Russian counterparties should review whether Rosreestr data, including records of recent transfers or re-registrations, may now be engaged more directly in their proceedings. Enforcement counsel should assess three steps: (1) confirm whether the relevant counterparty qualifies as a state-related entity under the applicable Russian law definition; (2) identify real property assets registered in the counterparty's name or in the name of connected entities in Rosreestr; and (3) evaluate whether any recent registration events — disposals, re-registrations, or pledge entries — are relevant to preferential transfer or asset-dissipation arguments.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Related reading:

• Ministry of Finance guidance on Rosreestr: /insights/atr-lu-002-ministry-of-finance-issues-guidance-on-rosree/
• Rosreestr as investigative tool — practice briefing: /insights/atr-pb-002-rosreestr-property-register-as-an-investigati/
• Asset Tracing & Recovery practice: /practices/asset-tracing-recovery/

Alert: important development in tracing bank accounts and financial flows in Russia for Korean creditors Effective: October 2027

Russian courts have materially tightened the procedural threshold for granting disclosure orders against Russian credit institutions in enforcement proceedings — a development that directly affects Korean creditors seeking to trace bank accounts and financial flows in Russia. Under the current procedural framework, courts now require a more stringent evidentiary connection between the debtor's identified account and the underlying debt instrument before any disclosure order will issue.

Korean creditors face a specific disadvantage in this environment. Unlike creditors from CIS member states, Korean entities cannot rely on any multilateral financial information-exchange framework with Russia — the bilateral legal assistance arrangements between Russia and South Korea do not extend to automatic financial disclosure in civil enforcement matters. All access to Russian banking data must therefore be pursued through Russian court channels, which have become more demanding precisely as the urgency of acting before asset dissipation increases. Creditors who delay instructing experienced Russian counsel risk losing the practical window for effective account tracing entirely.

Recommended steps:

1. Conduct an immediate review of any Russian enforcement judgments or arbitral awards in your possession — confirm whether a disclosure order application has been filed and, if not, assess whether the current evidentiary package meets the revised threshold.
2. Engage Russian legal counsel with asset tracing experience to prepare or supplement a disclosure application without delay. Early engagement is the primary factor in preserving traceability of financial flows.
3. Request a review of available enforcement pathways under our Asset Tracing & Recovery practice (/practices/asset-tracing-recovery/) — including parallel enforcement and interim asset protection measures that may not be affected by the tightened disclosure standard.

Speak to our team — info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including Korean trade and institutional creditors — on enforcement and financial flow tracing in Russian proceedings. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Important development in unwinding shell company structures with Russian elements Effective: January 2026

Russian courts have meaningfully narrowed the circumstances in which intermediate shell layers can insulate underlying Russian assets from creditor reach. For British creditors pursuing recovery through structures with Russian elements, this development affects both strategy and timing.

British creditors holding claims against debtors who have used multi-layer shell company structures to place Russian assets at a remove from direct enforcement have operated in a procedurally uncertain environment. The prevailing approach of Russian courts has, until recently, required creditors to demonstrate substantial evidence of asset-holding before applications to disregard intermediate entities would be entertained. Courts have increasingly moved to accept a lower evidentiary threshold at the application stage — while simultaneously tightening the deadlines within which such applications must be filed once insolvency or enforcement proceedings are opened. The practical effect is a narrower but more accessible window for unwinding shell company structures with Russian elements under Russian law.

For British creditors, the risk of delayed action is now materially higher. A debtor who files for insolvency in Russia — or who invites a friendly creditor to initiate proceedings — may use the procedural clock to foreclose the unwinding route before a foreign creditor has assembled its application. Conversely, creditors who move early and correctly may find Russian courts more receptive than prior practice suggested.

Recommended steps:

1. Identify any Russian-element shell layers in your debtor's corporate structure and map the asset-holding entities now, before proceedings are opened by any party.
2. Obtain a preliminary assessment of the evidentiary record available to support a disregard application under Russian civil and insolvency legislation.
3. Confirm whether any insolvency filing or enforcement action is already pending in Russia — the deadline position should be verified immediately.

For guidance on unwinding shell company structures with Russian elements, see our Asset Tracing & Recovery practice page and the related analysis at Legislative amendment affecting unwinding of shell company structures.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Action required — Cyprus-Russia corporate structures post-2022 against insolvency estates Effective: April 2026

Post-2022 Cyprus-Russia corporate structures are increasingly targeted in Russian insolvency estate proceedings. Russian insolvency practitioners and creditor committees are now pursuing transaction-challenge actions and asset recovery steps against Cyprus holding vehicles that received or retained Russian operating assets after 2022. Structures that were once administratively durable have become documented targets within estate proceedings under Russian law.

Foreign creditors holding claims against Russian entities whose assets sit within – or were transferred through – a Cyprus holding layer face compounded risk. In an increasing number of insolvency proceedings, estate managers are seeking to consolidate assets from Cyprus-registered vehicles into the Russian estate, relying on grounds including preferential transfer challenges and related-party transaction reversal. Secured creditors whose pledges run over Russian assets held under Cyprus ownership chains, and trade creditors whose counterparty is a Cyprus-registered entity with Russian operating subsidiaries, are both within scope. Creditors who have not yet assessed this exposure against their specific claim position should do so before claims submission deadlines in the relevant insolvency proceedings close.

Recommended steps:

1. Map your exposure. Confirm whether your claim runs against a debtor that forms part of a Cyprus-Russia ownership chain. Review the corporate structure as it stood immediately before any insolvency filing.

1. Obtain an asset-profile analysis. Commission a creditor-side review of the insolvency estate's known asset base and any pending or filed transaction-challenge proceedings that may affect recoverable value.

1. Engage Russian counsel before claims deadlines. Creditor participation rights in Russian insolvency proceedings are time-limited. Missing the initial claims submission window materially narrows the options available to foreign creditors at every subsequent stage.

The firm's Asset Tracing & Recovery practice advises foreign creditors in Russian insolvency proceedings, including matters involving Cyprus-Russia holding structures.

To discuss your position in confidence — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

— Elizaveta Razina Senior Lawyer, Practice Lead – Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors on recovery in Russian insolvency proceedings, including matters involving offshore holding structures. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

Alert: UAE real estate owned by Russian nationals — enforcement options under Federal Law 229-FZ on enforcement proceedings Effective: Immediate

Under Federal Law 229-FZ on enforcement proceedings, Russian-domiciled enforcement writs may identify foreign-sited assets — including UAE real estate owned by Russian nationals — as part of the formal enforcement record. This creates a documented evidentiary basis for parallel creditor action that foreign creditors should not overlook.

Foreign creditors holding Russian court judgments or arbitral awards against Russian nationals who own UAE real estate should note the following. Federal Law 229-FZ on enforcement proceedings does not itself confer direct execution rights over UAE-sited property. Russia and the UAE do not currently have a bilateral treaty on mutual recognition and enforcement of court judgments. The operative path combines Russian enforcement proceedings — which formally document the debtor's foreign assets in the FSSP record — with parallel proceedings before UAE courts, where a Russian judgment may be admitted as evidence in support of a fresh enforcement claim. Creditors who delay initiating either limb risk losing factual priority as debtor asset structures are reorganised.

Recommended action:

1. Confirm that the Russian judgment or arbitral award is final, enforceable, and officially translated — this document is the foundation of any UAE-side claim.
2. Instruct Russian counsel to initiate or review existing enforcement proceedings under 229-FZ and obtain formal Federal Service of Court Bailiffs (FSSP) documentation of the debtor's UAE assets, where identifiable.
3. Engage UAE-qualified counsel — in coordination with Russian enforcement proceedings — to assess the recognition route available before UAE courts and to consider interim asset preservation measures.

For further guidance on enforcing against UAE real estate owned by Russian nationals under Federal Law 229-FZ on enforcement proceedings, see our Asset Tracing & Recovery practice page and related briefings: UAE real estate owned by Russian nationals — regulatory update and Foreign creditors and UAE real estate owned by Russian nationals.

To discuss enforcement options for UAE real estate owned by Russian nationals — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on enforcement proceedings against Russian-domiciled debtors with foreign-sited assets, including coordinated multi-jurisdictional recovery strategies.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Action required — coordinating enforcement across Russia and foreign jurisdictions in the oil and gas sector Effective: immediately

Foreign creditors holding claims against oil and gas counterparties with Russian assets are increasingly encountering a specific coordination problem: enforcement steps taken in one jurisdiction can compromise, delay, or invalidate parallel proceedings under Russian law — sometimes irreversibly.

Oil and gas assets in Russia carry sector-specific characteristics that heighten this risk. Subsoil licences, pipeline infrastructure, and offtake agreements are subject to regulatory oversight by Russian authorities and are treated differently from standard commercial assets in Russian enforcement proceedings. A freeze or assignment pursued through a foreign court order, without prior coordination with Russian counsel, may trigger licence suspension, asset reclassification, or priority disputes with state-linked creditors — consequences that are difficult to reverse once enforcement has commenced.

The coordination window is narrowing. Where a Russian counterparty is approaching insolvency, Russian law establishes hard deadlines for creditor registration and challenge of preferential disposals. Foreign creditors who delay committing to a coordinated strategy across all jurisdictions risk losing their position in the Russian insolvency queue entirely, regardless of the strength of their underlying claim.

Recommended action:

1. Map all assets of the Russian counterparty across jurisdictions before commencing enforcement in any single forum — Russian courts, foreign courts, or arbitration.
2. Confirm with Russian counsel whether the Russian asset pool includes subsoil rights, licensed infrastructure, or state-partnership interests, as these require a separate enforcement analysis under Russian law.
3. Establish a coordination protocol between Russian and foreign counsel before any freezing application or enforcement step is filed.

For guidance on coordinating enforcement across Russia and foreign jurisdictions in the oil and gas sector, including asset mapping and Russian proceedings strategy, contact the firm's asset tracing and recovery team. Further analysis on coordination practice in cross-border enforcement is available at [/insights/atr-lu-007-court-practice-shift-on-coordinating-enforcem/].

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on enforcement strategy across Russian courts and in coordination with counsel in foreign jurisdictions. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Worldwide freezing orders and Russian-situated assets — action required at the freezing and interim relief stage Effective: immediately

Foreign creditors who have obtained, or are in the process of obtaining, a worldwide freezing order covering assets situated in Russia should be aware that Russian civil procedure does not provide for automatic enforcement of foreign interim relief. A worldwide freezing order granted by an English, Dutch, or other foreign court will not, as a general matter, bind Russian courts or compel Russian-domiciled custodians of assets without separate local proceedings. At the freezing and interim relief stage, the window for protecting your position in Russia is typically narrow and depends on parallel action taken promptly under Russian procedural law.

Who is affected. Foreign creditors and distressed investors who hold a worldwide freezing order — or who are preparing to apply for one — covering Russian-situated assets, including real estate, receivables owed by Russian entities, shares in Russian companies, and funds held in Russian financial institutions. Creditors instructing foreign counsel on a WFO application should ensure Russian-law considerations are addressed concurrently, not as a secondary step after the foreign order is sealed.

Recommended action.

1. Instruct Russian counsel immediately upon deciding to seek interim relief abroad, so that parallel Russian protective measures can be evaluated and, where available, filed within the same timeframe.
2. Identify and document Russian-situated assets at the outset — the scope of the WFO must be coordinated with the categories of asset that Russian civil procedure is capable of protecting through its own interim measures framework.
3. Do not assume that notification of the WFO to a Russian counterparty, or to a Russian bank or registrar, creates a binding obligation under Russian law. Separate local measures, applied for in the competent Russian arbitrazh court or court of general jurisdiction, are typically required to freeze assets at the Russian-law level.
4. Keep Russian counsel informed of the foreign court's timetable — Russian interim measures applications are time-sensitive, and delay at the Russian-law stage can result in asset dissipation that the foreign order cannot remedy.

For further context on the procedural interaction between worldwide freezing orders and Russian civil interim relief, see the firm's detailed analysis at Worldwide Freezing Orders and Russian-Situated Assets and the practical procedural guide at A Practical Guide to Worldwide Freezing Orders and Russian Assets. The firm's Asset Tracing & Recovery practice page sets out the full scope of available measures.

To discuss your matter — including parallel Russian proceedings and interim relief strategy — contact the team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: important development in OFAC sanctions intersection with Russian asset recovery strategy for Emirati creditors Effective: 15 April 2027

Emirati creditors pursuing asset recovery against Russian counterparties must now account for a tightening in the intersection between US OFAC sanctions compliance and the mechanics of Russian civil enforcement – an intersection that neither Russian law nor UAE domestic law resolves on its own. Creditors who have structured their recovery strategy under Russian law alone may find that execution steps which are entirely lawful under Russian procedure nonetheless engage OFAC licensing obligations where the creditor entity or its banking correspondents have exposure to the US financial system.

Emirati companies and family offices holding Russian trade debts, pledge security, or insolvency claims are directly in scope if their banking relationships run through US dollar correspondent accounts or if their holding structures include US-person elements. In those circumstances, receiving a payment – including a court-enforced transfer from a Russian debtor's account – may constitute a transaction requiring OFAC authorisation, regardless of whether the underlying Russian court order is entirely valid. Russian counsel can confirm the lawfulness of each step under Russian law; whether a given receipt of funds is permissible under OFAC's current framework is a question for US-qualified sanctions counsel, and the two analyses must run in parallel.

Recommended action:

1. Audit your recovery structure before the next enforcement step. Identify whether any element of the payment chain – correspondent bank, holding entity, or nominee – has US-person exposure that could bring OFAC into scope.
2. Instruct Russian law counsel to confirm which procedural steps are available and their sequencing, so that the Russian-law timeline is clear before US sanctions counsel assesses each step.
3. Obtain a written OFAC compliance position from US-qualified sanctions counsel before executing any transfer from a Russian account, pledged asset realisation, or insolvency distribution.
4. Review whether a specific licence application to OFAC is necessary and, if so, factor the processing timeline into your overall recovery schedule.

For a review of the Russian-law dimension of your recovery position – including asset identification, enforcement mechanics under Russian civil procedure, and insolvency creditor strategy – contact the asset tracing and recovery team at Vetrov & Partners. We work alongside your OFAC and UAE counsel to ensure the Russian-law steps are sequenced correctly.

Make an enquiry — info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

Further reading: Asset Tracing & Recovery | OFAC sanctions intersection with Russian asset recovery strategy | Federal Tax Service guidance: OFAC intersection

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors – including Emirati, European, and Asian trade creditors – on Russian enforcement, pledge realisation, and insolvency creditor strategy.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: important development in digital asset and cryptocurrency tracing in Russia against privately held Russian companies Effective: July 2027

Russian arbitrazh courts have materially expanded their approach to digital asset and cryptocurrency tracing in enforcement proceedings against privately held Russian companies. Under Russia's legal framework for digital financial assets, courts are now ordering operators of digital asset platforms and custodians to disclose wallet data and freeze cryptocurrency holdings at the creditor's application — a development with direct consequences for foreign creditors seeking recovery from Russian counterparties.

Until recently, tracing digital assets held by privately held Russian companies was practically and legally uncertain. Russian law privately held Russian companies were rarely subject to effective cryptocurrency disclosure obligations in civil enforcement proceedings. That position has shifted. Courts have increasingly treated digital financial assets as attachable property under general enforcement rules, extending existing freezing mechanisms to on-chain holdings. The practical effect is that a foreign creditor pursuing a Russian debtor can now apply to an arbitrazh court for interim measures that reach a counterparty's cryptocurrency wallet — provided the creditor can identify the relevant platform or demonstrate that the debtor holds digital assets.

Three points require immediate attention from foreign creditors with live or anticipated recovery claims against privately held Russian companies. First, the window for early application matters: interim measures in cryptocurrency tracing proceedings are typically granted on an ex parte basis, before the debtor can dissipate holdings. Delay reduces the effective pool of recoverable assets. Second, the disclosure and freeze mechanism operates under Russian law, not through MLAT or foreign court order — meaning a locally admitted counsel relationship is essential from the outset. Third, for creditors with EAEU or CIS exposure, parallel enforcement routes may be available; the interplay between Russian domestic enforcement and cross-border recognition frameworks warrants early review.

Foreign creditors should review open recovery claims against Russian counterparties to assess whether digital asset holdings may form part of the recoverable estate. Counsel instruction at the interim measures stage — before formal enforcement proceedings are issued — will preserve the widest range of options.

Further analysis is available in our publications on digital asset tracing in Russian proceedings and the Supreme Court's clarification on digital asset recovery. The firm's Asset Tracing & Recovery practice advises foreign creditors at all stages of Russian enforcement.

To discuss a live recovery matter — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Vetrov & Partners is a boutique Russian law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors on locating and enforcing against Russian-held assets, including digital financial assets and cryptocurrency holdings. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

Alert: Russian development affecting beneficial ownership disclosure in the FMCG and retail sector Effective: October 2027

Recent amendments to Russian corporate transparency legislation have extended mandatory beneficial ownership disclosure obligations to entities operating in the FMCG and retail sector. Under the revised framework, companies in this sector are now required to identify, verify, and disclose their ultimate beneficial owners — including those holding interests through offshore structures — within shortened reporting timelines and with enhanced documentary requirements.

Foreign creditors holding claims against Russian FMCG and retail counterparties — or monitoring potential insolvency in this sector — should be aware that non-compliant entities may face administrative sanctions, and that regulatory disclosure records are now more likely to be relied upon in enforcement and asset tracing proceedings. Where a Russian debtor or counterparty has previously obscured its beneficial ownership structure, the new disclosure obligations may make that structure more visible — and therefore traceable — through official channels. This represents a material development for creditors whose recovery strategy depends on identifying assets held through intermediate holding structures.

Recommended action:

1. Review any existing claims or monitoring positions against Russian FMCG or retail entities for potential beneficial ownership compliance gaps that may affect asset tracing strategy.
2. Consider requesting updated beneficial ownership information from Russian counterparties as part of ongoing credit and recovery management.
3. Obtain Russian legal advice before the next reporting deadline to assess how the new disclosure framework affects your specific recovery or enforcement position.

For advice on beneficial ownership disclosure obligations and asset tracing in Russia, contact our Asset Tracing & Recovery team. See also our related briefing on beneficial ownership disclosure obligations under Russian law: /insights/atr-pb-011-beneficial-ownership-disclosure-obligations-u/

Make an enquiry — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on beneficial ownership investigations, cross-border enforcement, and debtor asset analysis under Russian law. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Nominee arrangement risks and unwinding under Russian law for US creditors Effective: January 2026

Russian courts and enforcement authorities have materially tightened their scrutiny of nominee arrangements used to hold or shield assets from creditor claims. For US creditors pursuing recovery against Russian-law debtors, the prevailing approach now makes it considerably more difficult to rely on nominee structures as stable holding mechanisms — and simultaneously opens additional avenues to challenge such structures when they stand between a creditor and the underlying asset.

US creditors holding claims under Russian-law instruments — whether arising from trade finance, security arrangements, or arbitral awards — are directly affected where their debtor, or a related entity, has deployed nominee structures to place assets beyond reach. Russian courts have increasingly been willing to look through nominee arrangements and attribute assets to the beneficial owner for enforcement purposes. The same analytical framework that supports asset tracing by creditors has also begun to attract regulatory attention, as FAS Russia and other authorities scrutinise the use of such structures in commercial dealings. Creditors who have not yet mapped the nominee-arrangement risk within their recovery strategy may find that the recovery window narrows without warning.

Recommended steps for US creditors:

1. Audit existing recovery strategy to identify whether nominee arrangements are likely to be interposed between the debtor and attachable assets.
2. Obtain a Russian-law analysis of the specific nominee structure at issue — the grounds for unwinding vary according to how the arrangement was constituted and what evidence of beneficial ownership is available.
3. Consider the timing of enforcement action carefully: Russian insolvency proceedings, once commenced by or against the debtor, impose additional constraints on asset tracing claims and may affect the available grounds for challenging nominee arrangements.

For further analysis of how Russian courts approach nominee arrangements, see How Russian courts approach nominee arrangements in enforcement proceedings and FAS Russia enforcement trends in nominee arrangement cases. The firm's Asset Tracing & Recovery practice advises US and other foreign creditors on recovery strategy in this context.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including US-based institutional and trade creditors — on enforcement strategy, nominee arrangement analysis, and asset recovery in Russian proceedings. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Fraudulent transfer analysis under Russian civil law — pre-action investigation stage Effective: immediately

Foreign creditors holding claims against Russian counterparties should review their pre-action position without delay. Under Russian civil law, transactions that dissipate or encumber a debtor's assets may be challenged as voidable — but the procedural window for initiating that challenge, and for securing the evidentiary record that supports it, is narrower than creditors accustomed to common-law jurisdictions typically expect. Once assets have been transferred beyond reach, the scope for recovery through Russian courts narrows considerably.

Who is affected. This alert is relevant to foreign trade creditors, institutional investors, and distressed-asset holders with outstanding claims against Russian entities where there is reason to suspect that the debtor has, or may be, restructuring its asset base ahead of formal insolvency proceedings or enforcement. Russian civil law provides grounds to challenge transactions at an undervalue, transactions with related parties, and preferential disposals — but those grounds must be assessed and preserved at the pre-action stage, before the debtor controls the procedural timetable. Creditors who allow the investigation stage to lapse without documenting the transactional history risk losing the evidentiary foundation for a subsequent challenge in Russian courts or arbitrazh proceedings.

Recommended action. Foreign creditors should take the following steps as a matter of priority:

1. Commission a pre-action fraudulent transfer analysis covering the debtor's transactional record for the relevant look-back period under Russian civil law — the applicable period varies by transaction type and the legal basis for the challenge.
2. Identify and preserve documentary evidence of asset movements, related-party dealings, and valuations that may be required to support a voidable transaction claim before Russian courts.
3. Assess whether interim protective measures — including an asset freeze application before the competent Russian court — are available and appropriate given the current stage of proceedings.

For detailed guidance on the pre-action framework, see Asset Tracing & Recovery and the related briefing Foreign creditors and fraudulent transfer analysis in Russia.

To discuss your pre-action position in confidence — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on pre-action investigation, fraudulent transfer analysis, and interim relief applications before Russian courts. Partner-level involvement is maintained on every engagement from instruction through to resolution.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: important development in interim relief applications in Russian courts for Indian creditors Effective: July 2026

Russian arbitrazh courts have materially tightened the evidentiary standard they apply when considering interim relief applications — including asset preservation and freezing orders — filed by foreign creditors. In practice, courts are now requiring applicants to demonstrate a more direct and documented causal link between the assets sought to be preserved and the underlying claim. For Indian creditors pursuing recovery of debts or enforcement of contractual obligations in Russia, this shift represents a meaningful change to the procedural calculus that should inform any pending or planned interim relief application in Russian courts.

Indian creditors are directly affected by this development for two reasons. First, cross-border claims — where the creditor is domiciled outside Russia and the debtor or its assets are located within the Russian Federation — have historically attracted closer judicial scrutiny on the urgency and proportionality requirements. Second, the change applies across the arbitrazh court system, meaning it is relevant whether proceedings are filed in Moscow, Novosibirsk, or any other jurisdiction within Russia. Creditors who have already obtained interim relief should verify that the order remains enforceable under the current approach; creditors preparing applications should recalibrate their supporting documentation accordingly. The firm's Asset Tracing & Recovery practice regularly advises foreign creditors at this stage.

Recommended action:

1. Review any pending interim relief application and confirm that the supporting evidence satisfies the more demanding causal-link standard now being applied by Russian courts.
2. If an interim order has already been granted, assess whether the counterparty is likely to challenge continuation on the basis of the revised judicial approach.
3. Engage Russian-qualified counsel before filing or responding — the procedural window for interim measures under Russian procedural rules is typically narrow and does not accommodate iterative correction of deficient submissions.

Speak to our team about interim relief applications in Russian courts — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including those domiciled in India and other EAEU-adjacent jurisdictions — on interim relief strategy, asset preservation, and enforcement in Russian courts. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

Alert: Important development in third-party disclosure orders in Russian proceedings at the cross-border tracing stage Effective: October 2026

Russian arbitrazh courts have raised the evidentiary threshold for third-party disclosure orders at the cross-border tracing stage. Creditors whose applications previously succeeded on broadly framed information requests are now encountering procedural resistance that risks derailing recovery timelines.

Foreign creditors tracing assets across jurisdictions rely on third-party disclosure orders directed at Russian banks, registries, and professional service providers who hold records of a debtor's assets. Courts have increasingly required applicants to demonstrate, at the application stage, the specific category of information sought, the particular nexus between the third party and the debtor's assets, and proportionality between the disclosure sought and the recovery objective. Applications that do not meet this standard are now being declined or returned for amendment – a delay that can be critical when assets are at risk of dissipation. Creditors engaged in live cross-border tracing efforts should treat the procedural scaffolding of any pending or planned disclosure application as a live compliance risk.

Recommended action:

1. Review any pending third-party disclosure applications filed in Russian proceedings to confirm they specify the information category, the third-party nexus, and the proportionality basis with sufficient particularity under the current standard.

1. Where applications have already been declined or returned, assess whether amendment and resubmission is procedurally available within the applicable timeframe.

1. Engage Russian-qualified asset-tracing counsel before filing new disclosure applications – the current standard requires a more granular evidentiary scaffold than was previously the norm. See the firm's Asset Tracing & Recovery practice page for further context, and the related briefings at Third-Party Disclosure Orders in Russian Proceedings and A Practical Guide to Third-Party Disclosure Orders.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on third-party disclosure applications, cross-border tracing, and enforcement proceedings before Russian courts.

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

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

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

In advising foreign law firms on Russian asset-tracing mandates over recent years, a recurring procedural question surfaces early in almost every matter: what evidentiary weight will a Russian court assign to corporate registry information obtained by a foreign creditor acting without local counsel? A ruling handed down by Russia's supervisory court in the first half of 2026 has directly addressed that question, and the answer carries practical consequences for any firm coordinating cross-border asset recovery that touches Russian corporate structures.

The proceedings arose from an attempt by a foreign creditor to locate and freeze assets held through a chain of Russian legal entities. At the pre-enforcement stage, the creditor's foreign advisers had sourced corporate registry extracts directly from the Unified State Register of Legal Entities (EGRUL) through the Federal Tax Service's public portal, without instructing Russian counsel and without formal authentication of the retrieved data under Russian procedural rules. Those extracts were then presented to a Russian arbitrazh court in support of an application for interim measures — specifically, a prohibition on asset disposal pending resolution of the underlying claim.

The court of first instance declined the application. The appellate instance upheld that refusal on narrow procedural grounds, without resolving the underlying evidential question. When the matter reached the cassation level and was subsequently elevated to supervisory review, the higher court took the opportunity to issue guidance with broader application.

The central legal question was this: are EGRUL extracts obtained through a public access mechanism, without certification or notarial confirmation, and without the involvement of a party with procedural standing in the Russian proceedings, admissible as a basis for interim measures in Russian civil and commercial courts?

The supervisory court declined to treat the raw digital extracts, submitted directly by the foreign party, as sufficient evidentiary foundation for the interim relief sought. The court's reasoning rested on two related grounds.

First, the court held that, while EGRUL data is publicly accessible, its procedural use in support of an interim measures application requires that the data be obtained and introduced into the record by a participant in the proceedings with established standing under Russian civil procedure. A foreign party submitting materials directly — particularly where the Russian representation formalities had not been completed — could not satisfy that standing requirement.

Second, and of broader significance, the court addressed the issue of extract currency. EGRUL data on the public portal reflects a snapshot that may be days or weeks behind the live register at the moment of filing. The court noted that interim freeze applications are, by their nature, time-sensitive; a stale extract that does not capture recent re-registrations, director changes, or share transfers may affirmatively mislead the court as to the asset position being frozen. The court indicated that, for interim measures purposes, registry data should be sourced at the time of filing and introduced through counsel with knowledge of its limitations.

The court remitted the matter for reconsideration, with the original interim measures application to be re-examined with properly introduced and current registry evidence.

"This ruling is significant less for what it prohibits than for what it clarifies: Russian corporate registry searches, when used to ground interim relief, are procedural acts requiring counsel involvement — not merely a research step a foreign party can complete independently." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For partners at foreign firms coordinating Russian asset-tracing work, the ruling's practical implications divide into two categories: evidentiary procedure and timing.

On evidentiary procedure, the ruling confirms a position that experienced Russian practitioners have long applied in practice, but which had not previously received clear supervisory endorsement. Corporate registry searches conducted for the purpose of supporting an interim measures application — or any application that turns on the present ownership, control, or asset composition of a Russian entity — need to be conducted through local counsel who is already (or simultaneously being) enrolled as a party representative in the Russian proceedings. The introduction of that evidence into the record is itself a procedural act, not merely an administrative one.

For firms that currently send clients to the public EGRUL portal as a first step in asset scoping, this ruling counsels an adjustment: EGRUL searches remain a useful preliminary tool for assessing the landscape, but the moment those results are intended for use before a Russian court, local counsel involvement is required at the point of retrieval and filing, not merely at the point of advocacy.

On timing, the ruling's emphasis on extract currency has immediate consequences. EGRUL data used in an interim measures context should reflect the register as at the date of the application — or as close to it as is practically achievable. The standard practice at Vetrov & Partners for asset-tracing mandates is to obtain fresh registry extracts immediately prior to filing, with a timestamped record of retrieval. This approach is now directly supported by the court's reasoning.

For foreign counsel, the ruling also underscores the value of instructing Russian local counsel at the intelligence-gathering stage, not only once a claim is being formulated. The question of what corporate registry searches will support a future application is one that benefits from early-stage input from counsel who understands both the registry's architecture and Russian procedural requirements for evidence introduction.

For firms advising foreign creditors with Russian counterparties, establishing a confirmed local counsel relationship before interim measures become urgent is the more practical approach to protecting the client's position.

If you are coordinating an asset-tracing matter with a Russian dimension — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Corporate registry searches in Russia: a legal update
• A practical guide to Russian corporate registry searches for asset tracing
• Asset Tracing & Recovery practice overview

Q: What does this ruling change?

A: The ruling does not create a new procedural prohibition but provides the first clear supervisory endorsement of a position practitioners had applied in practice without explicit high-court authority. Russian corporate registry data — specifically EGRUL extracts — when used in support of an interim measures application, must be obtained and introduced into the record by counsel with procedural standing in the relevant Russian proceedings. Foreign parties submitting such data directly, without Russian representation in place, face a material risk that the court will decline to treat those materials as admissible evidential foundation. The ruling also addresses currency: extracts must reflect the register as at the time of filing, which is especially significant where share transfers or restructuring may have occurred recently.

Q: What should foreign companies do in light of this decision?

A: Foreign companies and their advisers should treat EGRUL corporate registry searches as procedurally connected to the litigation strategy from an early stage. If there is any prospect that registry data will be relied upon before a Russian court — whether for interim measures, enforcement, or related proceedings — that data should be sourced by locally instructed Russian counsel at the time of filing, with a timestamped retrieval record. Using the public EGRUL portal for initial orientation is reasonable; treating those results as court-ready evidence without counsel involvement is not, following this ruling. Foreign law firms coordinating Russian asset-tracing mandates should confirm local counsel instructions before the interim measures question becomes live, rather than at the point when urgency is already a factor. Early instruction enables counsel to conduct registry searches in a form that satisfies procedural requirements from the outset.

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

The firm's asset tracing and recovery practice advises foreign creditors, international law firms, and institutional recovery specialists on locating and preserving Russian assets across corporate, real estate, and financial asset classes. The practice covers corporate registry analysis, interim measures, enforcement proceedings, and cross-border coordination with instructing counsel. 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/

In practice, the assumptions foreign law firms bring to Russian property investigations tend to run ahead of what Russian courts actually permit. The Rosreestr property register – Russia's unified state register of immovable property – has long been treated in cross-border proceedings as a reliable index of what a Russian counterparty owns. A recent Russian court decision has materially sharpened that picture. It affirmed that Rosreestr property register data may serve as a primary investigative instrument in identifying assets held, directly or indirectly, by parties whose ownership is obscured by intermediate offshore structures. For firms instructing Russian lawyers on enforcement and asset recovery mandates, the ruling alters both the analytical starting point and the scope of what register-based inquiries can reach.

The case arose from a commercial dispute in which a foreign creditor sought to enforce a monetary judgment against a Russian respondent. The respondent's declared assets were insufficient to satisfy the judgment, and the creditor's advisers had reason to believe that immovable property of material value was held through a chain of intermediate entities with offshore links. The central question before the court was whether Rosreestr data – ordinarily accessible only in respect of a named registered owner – could be accessed or disclosed in a manner that allowed the creditor and its counsel to interrogate ownership more broadly: specifically, to trace from a known property address or cadastral reference back through layers of registered title to identify beneficial exposure.

The case engaged long-standing procedural tensions in Russian civil proceedings: the boundary between information that a court may compel a register to disclose and information that remains protected as third-party data. It also raised the question of how Russian law treats register-derived evidence when the registered owner is a foreign entity and the underlying interest is held through a structure with no obvious Russian registered presence. For foreign law firms advising creditors or counterparties in similar positions, the procedural framework that the court was asked to interpret is one that appears in asset-tracing and enforcement matters with increasing frequency.

The court held that Rosreestr constitutes a state register whose data, in the context of litigation where asset identification is directly at issue, may be accessed through a court-ordered disclosure mechanism. Critically, the ruling addressed the scope of that mechanism: it confirmed that a request framed by reference to a cadastral object – rather than solely by reference to a named owner – is procedurally permissible, and that the register may be required to confirm historical title records, including transfers that predate the commencement of proceedings. The court declined to read the data-access provisions of the registration legislation narrowly, finding that the protective purpose of those provisions was directed at preventing arbitrary commercial inquiry, not at insulating assets from judicial oversight in active enforcement proceedings.

The court also addressed what happens when the registered owner is a foreign legal entity with no separate Russian registration. It found that the absence of a Russian legal presence did not extinguish the court's authority to examine the Rosreestr record, because the subject matter of the inquiry – the immovable property itself – is located within Russian jurisdiction. The court's reasoning drew on the principle that immovable property situated in Russia is governed by Russian law regardless of the ownership structure above it.

"What this decision does is close a procedural gap that offshore structuring frequently relied upon – the assumption that title registered in a foreign entity's name would place the beneficial question beyond the reach of a Russian enforcement court." – Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

For foreign law firms building an asset-tracing strategy that relies on Russian register data, early instruction of local counsel is material to framing the court request correctly. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical consequences of this ruling operate at two levels. The first is procedural: Russian counsel can now frame applications for Rosreestr disclosure with greater confidence where the ownership of the relevant property is not transparent from the face of the register. In matters where a creditor's primary difficulty has been identifying what the respondent actually owns rather than what it declares, the decision provides a clearer procedural pathway. The second level is strategic: for foreign parties on either side of Russian enforcement or asset-tracing proceedings, the ruling changes the risk calculus around structures that interpose offshore intermediaries between an ultimate beneficial owner and Russian immovable property.

For firms instructing Russian lawyers in the context of post-judgment enforcement, the ruling also has implications for the sequencing of investigative steps. The question of whether to seek Rosreestr access early in proceedings – before the respondent has the opportunity to take steps in relation to the registered title – is now more tractable as a matter of Russian procedural law. The risk of delay is correspondingly more concrete: title transfers in Russia are effective upon registration, and a Rosreestr record that reflects ownership today may not do so in three months if pre-emptive restructuring takes place. This is a risk that foreign creditors familiar with interim remedies in their own jurisdictions will recognise, even if the Russian procedural tools available to address it differ in form.

More broadly, the decision is a useful indicator of the direction in which Russian courts are interpreting the balance between register confidentiality and enforcement transparency. The prevailing approach, as reflected in this and related decisions, places the interests of active enforcement proceedings above the data-protection rationale that has sometimes been used to resist register-based inquiries. Foreign parties whose Russian asset exposure is channelled through intermediate structures should treat this as a material development in the legal landscape of Russian asset tracing.

Vetrov & Partners acts for foreign creditors and foreign law firms in asset-tracing and enforcement matters before Russian courts. To discuss how this ruling applies to a specific mandate, contact info@vetrovpartners.com or reach the team directly on WhatsApp / Telegram: +7 (983) 510-38-76

Q: What does this ruling change?

A: Before this decision, there was meaningful ambiguity in Russian procedural practice about whether a Rosreestr disclosure request could be framed by reference to a cadastral object rather than a named registered owner, and whether foreign-registered ownership entities fell outside the court's effective reach. The ruling resolves both points in favour of broader access: courts may compel object-referenced disclosure, and foreign registration of an owning entity does not shield the Russian property record from judicial inquiry. The practical change is that asset-tracing strategies anchored in Rosreestr data are now on firmer procedural ground when pursued through Russian courts, particularly where the ownership structure above the property involves offshore intermediaries. Firms that have previously treated the register as a limited resource in such cases should revisit that assessment in light of this decision.

A: What should foreign companies do in light of this decision?

Q: What should foreign companies do in light of this decision?

A: Foreign companies with Russian immovable property interests held through non-Russian entities should review the current Rosreestr registration position of those assets and consider whether the existing structure remains adequate in light of the expanded judicial access this decision reflects. For foreign creditors in active or anticipated enforcement proceedings against Russian counterparties, the priority is to instruct Russian counsel promptly – the window between the commencement of proceedings and any title movement on the register may be narrower than expected. For foreign law firms advising in either capacity, this ruling is a relevant development to bring to clients with Russian property exposure. Vetrov & Partners is available to provide a targeted briefing on the implications for a specific matter or portfolio.

• Ministry of Finance issues guidance on Rosreestr data access in enforcement proceedings
• Rosreestr property register as an investigative tool: a practitioner's guide
• Asset Tracing & Recovery practice

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

The firm's Asset Tracing & Recovery practice advises foreign creditors, foreign law firms, and institutional clients in identifying, tracing, and recovering Russian assets through judicial and non-judicial channels. With over 1,000 matters handled since inception, the team provides partner-level involvement throughout, with direct English-language communication and no delegation to fee-earners.

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/

In advising foreign firms on cross-border enforcement against Russian debtors, one procedural question recurs with particular urgency: how reliably can a creditor locate the debtor's bank accounts and map its financial flows through the Russian court system? A decision handed down by a Russian arbitrazh court in late 2026 sheds useful light on both the scope of disclosure available and the procedural route for obtaining it. For law firms instructing Russian counsel on enforcement mandates, the ruling clarifies what can realistically be pursued — and, equally, where the limits of tracing bank accounts in Russia currently sit.

The proceedings arose from a commercial debt claim brought by a foreign creditor that had obtained an enforceable judgment against a Russian corporate debtor. The creditor's principal difficulty was a familiar one in cross-border enforcement practice: the debtor had ceased voluntary payment and its disclosed Russian assets were insufficient to satisfy the judgment. To mount a meaningful enforcement strategy, the creditor needed to identify the debtor's active bank accounts and to understand the pattern of financial flows between the debtor and its related entities.

The central legal question before the court was whether the creditor — acting through the Federal Bailiff Service — could compel disclosure of current account information held across multiple Russian credit institutions, and whether the scope of that disclosure could extend to recent transactional data rather than merely to the existence of the accounts themselves.

The matter came before the arbitrazh court on the creditor's application to confirm the bailiff's authority and the breadth of the disclosure obligation. The case warrants attention because the debtor contested the scope of the request, arguing that transactional data fell outside the statutory framework governing enforcement-stage disclosure.

The court rejected the debtor's objection and confirmed that the Federal Bailiff Service holds authority to request, from Russian credit institutions, not only confirmation of account existence but also recent transactional data where such information is necessary to identify assets subject to enforcement. The court reasoned that the statutory purpose of the enforcement regime — full satisfaction of a creditor's judgment — would be materially frustrated if debtors could shield financial flows from disclosure simply by arguing that transactional detail exceeded the scope of a formal account inquiry.

The ruling further held that where a debtor operates through a network of related entities, the bailiff's disclosure requests may extend to accounts held by those entities where there is a credible factual basis to conclude that assets have been transferred between them. This is a meaningful development in the Russian court tracing bank accounts framework, and one with direct operational relevance for enforcement against debtors that have restructured their financial arrangements since the underlying obligation arose.

"This ruling confirms that Russian enforcement procedure, correctly applied, gives creditors real investigative reach — but the factual groundwork for extending disclosure to related entities must be laid before the application is filed." — Elizaveta Razina, Senior Lawyer, Practice Lead — Asset Tracing & Recovery, Vetrov & Partners

For foreign law firms currently instructing or preparing to instruct Russian lawyers on enforcement mandates of this nature, the decision is a useful reference point on what the procedure can deliver.

If your client holds an enforceable judgment against a Russian debtor and requires local counsel to pursue tracing bank accounts in Russia — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For practitioners advising clients with Russian enforcement targets, the ruling has three practical consequences worth noting before instructions are placed.

First, the scope of the bailiff's disclosure authority is broader than many foreign practitioners assume. Tracing bank accounts in Russia at the enforcement stage can extend to transactional history and, in appropriate circumstances, to the accounts of related entities — not merely to a list of current account numbers. This meaningfully increases the investigative value of enforcement-stage disclosure and reduces the gap between what Russian procedure offers and what is achievable through pre-litigation asset investigation.

Second, the evidentiary threshold for extending disclosure to related entities is not trivial. The creditor must establish a credible factual connection between the primary debtor and the entities in question before the application is filed. In practice, this means that Russia ruling foreign parties in enforcement matters is not a purely reactive exercise — preparatory work, often combining public registry searches and commercial intelligence, is necessary to frame an application that will succeed. Firms instructing Russian lawyers for the first time on an enforcement mandate should expect and budget for this investigative stage.

Third, the procedural sequencing matters and is frequently misunderstood. The ruling confirms that the disclosure application must be made within the live enforcement proceedings, not as a freestanding application. Local counsel Russia with specific enforcement-stage experience will understand this sequencing automatically; the instruction should nonetheless confirm this explicitly when scoping the engagement. For firms seeking to coordinate a multi-jurisdictional asset tracing strategy in which Russian enforcement is one strand, Asset Tracing & Recovery sets out the firm's approach in detail.

Further background on the Russian Supreme Court's approach to tracing and disclosure in enforcement proceedings is available in our analysis at Russian Supreme Court clarification on tracing, and a practical overview of the procedure for firms new to this jurisdiction can be found at Navigating tracing bank accounts and financial flows.

To discuss a tracing bank accounts matter in Russia or to establish a local counsel relationship — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Russian Supreme Court clarification on tracing in enforcement proceedings
• Navigating tracing bank accounts and financial flows in Russia
• Asset Tracing & Recovery — practice overview

Q: What does this ruling change?

A: The ruling clarifies two points that were previously uncertain in Russian enforcement practice. First, it confirms that the Federal Bailiff Service's disclosure authority extends to transactional data from Russian credit institutions — not merely to account existence — where such data is necessary to identify assets. Second, it establishes that disclosure can be extended to related entities of the primary debtor where a credible factual basis for asset transfer is put before the court. Together, these points broaden the effective reach of tracing bank accounts in Russia at the enforcement stage and make enforcement-stage disclosure a more reliable investigative tool than it was previously understood to be in some circuits.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors and their advisers with live enforcement mandates against Russian debtors should reassess the scope of disclosure requests currently being made through the Federal Bailiff Service. Where the debtor is known or suspected to operate through related entities, the ruling supports a broader application — but only if the factual basis is established in advance. Practically, instructing Russian lawyers foreign firms should ensure that their local counsel is engaged early enough to conduct the preparatory investigative work before the enforcement application is filed. Firms without an established Russian counsel relationship who are approaching enforcement for the first time are welcome to make an enquiry at info@vetrovpartners.com.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years and 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 acting as instructing counsel on the identification, tracing, and enforcement of Russian assets — including tracing bank accounts, financial flows, and real property interests through Russian court and administrative proceedings. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of Russian enforcement practice with 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 — Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

In advising foreign law firms on Russian-element recovery matters over recent years, one recurring gap stands out: the assumption that a shell company structure assembled outside Russia insulates assets from unwinding proceedings before Russian arbitrazh courts. A recent Russian court decision has made that assumption considerably more difficult to sustain, and the implications for foreign counsel instructing local Russian lawyers are both immediate and practical.

Asset structures involving a Russian operating company, one or more intermediate holding layers in offshore or low-tax jurisdictions, and an ultimate beneficial owner registered abroad are familiar to practitioners across many practice areas. They arise in M&A transactions, creditor security arrangements, and joint-venture governance. The question that has repeatedly come before Russian arbitrazh courts is whether a transfer of Russian assets — whether shares, real property, or receivables — through such a layered structure can be challenged and unwound, particularly where the transfer was designed to place those assets beyond the reach of creditors or a competing claimant.

In the matter under review, the principal legal question concerned the standard of proof and the breadth of parties who could be drawn into unwinding proceedings before the arbitrazh court. Specifically, the court was asked to determine whether a claimant — in this instance a creditor with a judgment debt against a Russian entity — could pursue the reversal of a multi-step cross-border transfer where the intermediate steps had been completed through entities registered outside Russia. The respondent argued that the Russian court lacked the jurisdictional basis to examine transactions effected abroad and that the beneficial-ownership analysis required was beyond the permissible scope of domestic insolvency and asset-recovery proceedings.

The factual background, stripped of identifying detail, involved a chain of transactions spanning two jurisdictions beyond Russia. The Russian operating company had transferred its principal productive asset — commercial real estate in the Siberian Federal District — to an intermediate entity registered in a CIS member state, which in turn transferred the asset to an offshore holding company. The entire sequence was completed within a compressed timeframe and at below-market consideration. The creditor initiated proceedings in the Russian arbitrazh court seeking to unwind all steps in the chain.

The arbitrazh court upheld the claimant's case in material part. On the jurisdictional point, the court held that where the subject matter of the disputed transaction — here, Russian commercial real estate — remains governed by Russian property law regardless of the nationality or registration of the intermediate transferee, the arbitrazh court retains the competence to examine the entire transaction chain. The cross-border character of the intermediate steps did not sever the Russian court's connection to the underlying asset.

On the standard of proof, the court confirmed that the claimant need not demonstrate a specific fraudulent intent at each link in the chain. It was sufficient to establish, cumulatively, that the transactions were interconnected, that the overall result was the removal of a Russian asset from a position in which it was available to satisfy the creditor's claim, and that the consideration received at one or more steps was materially below market value. The court characterised this as a compound-transaction analysis: the chain is assessed as a whole, not as a series of independent disposals.

The court also addressed the status of the intermediate entities. It held that where an intermediate party cannot demonstrate independent commercial purpose for its role in the transaction, it may be treated as a conduit — a characterisation that then allows the court to look through that party and assess the economic substance of the chain directly. The conduit finding does not require evidence of the intermediate party's subjective awareness of the overall scheme; objective indicia — compressed timeline, below-market consideration, absence of board-level deliberation records — are sufficient.

"This decision reflects a clear doctrinal direction in Russian arbitrazh practice: courts are prepared to look through formal cross-border structures to the Russian asset at the end of the chain, applying a substance-over-form analysis that will be familiar to English and Dutch practitioners but which operates through distinct Russian procedural mechanisms." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign law firms advising clients with Russian-element recovery matters, early coordination with local Russian counsel is the most reliable way to assess whether a transaction chain is exposed under this approach — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For practitioners at foreign firms who instruct Russian lawyers on asset-tracing and recovery matters, the practical significance of this decision operates on three levels.

First, the compound-transaction analysis substantially widens the scope of structures that may be challenged. A structure that would previously have appeared adequately insulated — because each individual transfer step, taken alone, could be characterised as a conventional commercial transaction — may now be assessed in its entirety. Foreign counsel advising on structures with Russian underlying assets should treat the overall economic result, not the form of each step, as the operative legal test.

Second, the conduit characterisation introduces a new pressure point in transaction due diligence. Where an intermediate entity holds a Russian asset or a Russian operating company and cannot point to genuine board deliberation, independent financial advice, or an independent commercial rationale for its participation in the transaction, it risks being characterised as a conduit in subsequent proceedings. For firms advising on M&A transactions or creditor security arrangements involving Russian elements, this means that the governance documentation for each intermediate layer is not a formality — it is a material evidential record.

Third, and of direct relevance to firms instructing Russian lawyers in the context of enforcement: the ruling confirms that Russian asset freeze applications — interim measures sought in the arbitrazh court to preserve assets pending a full unwinding claim — can be grounded in a compound-transaction argument from the outset of proceedings. This makes early-stage coordination between foreign counsel and local Russian counsel, including a rapid assessment of the transaction chain and the availability of interim relief, considerably more consequential than it may have appeared under prior practice.

For in-house teams at foreign creditors and for litigation partners at foreign law firms seeking to instruct experienced Russian lawyers, the key operational shift is this: exposure analysis for any Russian-element structure must now account for the entire chain, and that analysis needs to be conducted before, not after, an adverse party begins proceedings.

If you are advising a client with a Russian-element recovery matter and need a rapid assessment of exposure under this approach, speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Legislative amendment affecting the unwinding of shell company structures with Russian elements
• Unwinding shell company structures with Russian elements: a practitioner overview
• Asset Tracing & Recovery in Russia

Q: What does this ruling change?

A: The ruling sharpens the analytical framework Russian arbitrazh courts apply when assessing multi-step cross-border transfer chains involving Russian assets. Prior to decisions of this kind, there was meaningful uncertainty as to whether a Russian court would examine intermediate steps completed through foreign-registered entities. The decision confirms that where the underlying asset is Russian — real property, shares in a Russian company, receivables governed by Russian law — the court will assess the entire transaction chain as a composite whole. Each link is not evaluated in isolation. The practical change is that structures which rely on the cross-border character of intermediate steps to resist unwinding proceedings are considerably more exposed than a step-by-step analysis would suggest.

Q: What should foreign companies do in light of this decision?

A: Foreign companies — and the law firms advising them — should conduct an immediate review of any structure with Russian underlying assets where one or more intermediate steps in the ownership or transfer chain were completed through entities outside Russia. The review should address three points: whether each intermediate entity can demonstrate independent commercial purpose, whether transaction documentation at each step is sufficient to rebut a conduit characterisation, and whether the overall consideration received across the chain reflects market value. Where exposure is identified, the priority is to understand the availability of interim relief under Russian procedure and the timeline within which an adverse party could bring a claim. Early instruction of local Russian counsel — before proceedings are commenced by an opposing party — remains the most effective protective step.

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

The firm's Asset Tracing & Recovery practice advises foreign creditors, foreign law firms, and institutional claimants on Russian-element recovery matters, including unwinding proceedings, interim asset preservation, and cross-border enforcement coordination. 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/

In the period since 2022, a line of Russian cassation court decisions has materially altered how Cyprus-Russia corporate structures are treated when Russian assets are in dispute. For foreign law firms advising clients whose Russian holdings sit inside Cypriot holding layers, this is not a theoretical risk: it is a live procedural reality that shapes what claims are possible, which entity can bring or defend them, and whether intercompany arrangements hold their intended effect. The decisions in question do not operate in isolation — they accelerate a judicial trend toward look-through analysis that Russian commercial courts had been developing for several years, but which cassation review has now consolidated into something approaching a consistent standard.

Cyprus-Russia corporate structures were, for most of the period from the early 2000s onward, the default architecture for Russian inbound and outbound investment. A Cypriot holding company owning a Russian operating subsidiary offered a combination of treaty protection, structural flexibility, and recognised corporate governance standards. That logic survived several rounds of Russian legislative reform — changes to controlled foreign corporation rules, beneficial ownership requirements under Russia's domestic tax framework, and the repatriation measures introduced in successive Finance Ministry circulars. What it did not fully survive was the combined effect of the suspension and subsequent termination of the Russia-Cyprus double taxation convention, which became effective from August 2023, alongside a concurrent shift in Russian court attitudes toward the structural independence of Cypriot entities. The cases that reached the cassation level from late 2022 onward arose predominantly from disputes between Russian creditors and Russian debtors where the debtor had routed assets through Cypriot entities. In the leading pattern, a creditor sought to enforce against the Russian operating subsidiary, only to find that the Russian debtor had transferred economic value to the Cypriot parent in the preceding period. The question before the cassation courts was whether those transfers were voidable, whether the Cypriot entity could be treated as a related party for the purpose of preference-claim analysis, and whether beneficial ownership doctrine could be applied to look through the Cypriot structure to the ultimate Russian beneficiary.

The cassation courts that addressed these questions, across a cluster of decisions reviewed in the period from late 2022 through mid-2024, reached broadly consistent conclusions on three points. First, the courts confirmed that the existence of a validly incorporated Cypriot entity does not, of itself, insulate transactions between that entity and its Russian subsidiary from voidability analysis under Russian insolvency legislation. The corporate veil was not treated as a jurisdictional barrier but as one factor in an overall assessment of transaction substance. Second, the courts applied beneficial ownership and related-party analysis with considerably more rigour than lower courts had been willing to do in earlier proceedings. Cypriot entities that lacked substantive operational footprint in Cyprus — measured by staffing, local contracts, and genuine decision-making capacity — were treated as related parties of the Russian operating entity, notwithstanding separate legal personality. Third, and most consequentially for foreign advisers, the cassation courts confirmed that Russian courts retain jurisdiction to examine the economic substance of a Cypriot entity's position even where the transaction documents were governed by English or Cypriot law. The governing law of the underlying agreement was treated as relevant to contractual interpretation but not determinative of the question whether the transaction itself was a preference or a fraudulent transfer under Russian law.

"What the cassation pattern signals to instructing foreign firms is that the structural independence of a Cypriot holding layer can no longer be assumed in Russian proceedings — courts are now conducting genuine substance analysis, and the results have been adverse for structures that existed primarily on paper." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign law firms advising clients with Russian assets held through Cypriot or other offshore structures, early engagement with Russian counsel is now a material step in any dispute assessment — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For a foreign law firm instructing Russian counsel in matters involving Cyprus-Russia corporate structures, the cassation pattern has three immediate practical implications. The first is in pre-litigation analysis. Before commencing or defending proceedings involving a Russian operating entity that sits within a Cypriot holding structure, it is necessary to assess the substance of the Cypriot entity's position under the criteria Russian courts have now articulated. That means reviewing board composition, local contracts, banking relationships, and the flow of economic decision-making. Structures that fail this analysis on the Russian side create exposure to related-party characterisation with significant consequences for claims, security, and intercompany debt. The second implication concerns the enforceability of intercompany arrangements. Russian courts have been reluctant to recognise the priority of intercompany loans and service agreements between a Russian subsidiary and its Cypriot parent where those arrangements lack economic substance. Foreign advisers who have structured client positions on the assumption that intercompany debt would be recognised at face value in Russian proceedings should treat that assumption as requiring re-examination. The third implication is procedural. Foreign firms instructing Russian lawyers on these matters will benefit from counsel who understands both the look-through doctrine as it has developed in Russian commercial court practice and the practical limitations on cross-border evidence gathering. The cassation decisions examined here were largely decided on the basis of Russian-law analysis and documentary evidence available within the Russian jurisdiction. Arguments that required reliance on Cypriot corporate formalities without supporting evidence of economic substance were consistently unsuccessful. Foreign firms can access a detailed review of the current Asset Tracing & Recovery practice landscape, including related developments in this area, through the cluster articles on Roskomnadzor enforcement trends and Cyprus-Russia structures and how Russian courts approach Cyprus-Russia corporate structures.

If you are instructing Russian counsel on a matter involving offshore asset Russia holdings or a Cyprus-Russia corporate structure, a complimentary initial 30-minute meeting is available — contact info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Roskomnadzor enforcement trend: Cyprus-Russia structures
• How Russian courts approach Cyprus-Russia corporate structures
• Asset tracing and recovery in Russian proceedings

Q: What does this ruling change?

A: The cassation pattern consolidates a shift that had been developing across Russian commercial courts but had not previously been confirmed at the cassation level with consistency. The core change is that Cypriot holding entities in Cyprus-Russia corporate structures can now be subjected to substance analysis by Russian courts when Russian insolvency law or asset recovery rules are engaged. A Cypriot entity that lacks genuine operational footprint may be treated as a related party of the Russian subsidiary, exposing intercompany transactions to voidability challenge. The dissolution of the Russia-Cyprus double taxation convention from August 2023 removed one of the principal structural incentives for these arrangements and has reinforced the courts' appetite to examine substance rather than form. Governing law clauses pointing to English or Cypriot law do not oust Russian courts' jurisdiction over the substantive transaction analysis under Russian law.

Q: What should foreign companies do in light of this decision?

A: Foreign companies and their advisers should undertake a substance review of any Cypriot entity in the holding chain that has contractual or financial dealings with a Russian operating subsidiary. The review should document board-level decision-making, local staffing and operational contracts in Cyprus, and the economic rationale for intercompany arrangements. Where a Russia-focused matter is already in dispute or is anticipated, instructing Russian counsel with experience in asset tracing and recovery — and specifically in the judicial treatment of offshore asset Russia holding structures — should be treated as an early priority. Legal opinions produced in a foreign jurisdiction will not, on their own, resolve the Russian-law questions that Russian cassation courts have now confirmed are within their reach.

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 and recovery practice advises foreign creditors, offshore holding structures, and international law firms requiring local counsel on Russian proceedings involving corporate structures, insolvency, and cross-border enforcement. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

Among the recurring challenges encountered in advising foreign creditors on Russian asset tracing, one pattern has grown notably more prominent: the debtor whose disclosed Russian estate appears modest but who holds substantial real estate in the United Arab Emirates, registered in their own name. Recent Russian court decisions have begun to address, with varying degrees of analytical rigour, how those assets figure in enforcement — and the results carry direct implications for foreign counsel considering whether to instruct local Russian lawyers for the recovery phase.

The legal question at the centre of these proceedings is deceptively straightforward: can a Russian court, adjudicating a monetary claim or enforcing an existing judgment against a Russian national, take cognisance of real property that debtor holds in the UAE, and — if so — in what procedural form can that recognition translate into recovery?

The cases that have reached Russian courts in recent years typically share a common factual profile. A creditor, often a trade counterparty or a financial institution, obtains a judgment or arbitral award against a Russian individual. Domestic enforcement proceedings reveal limited or encumbered Russian assets. The creditor — or its counsel — then identifies, through open-source registry data, professional valuation records, or information obtained during related divorce or inheritance proceedings, that the debtor holds one or more residential or commercial properties in Dubai or Abu Dhabi. The question of what Russian courts will do with that information has until recently been underexplored.

In a series of rulings handed down in recent years, Russian courts of general jurisdiction have reached conclusions that, while not uniform, establish several working propositions. First, courts have been willing, at least in principle, to treat UAE real property as a component of the debtor's overall asset base for the purposes of determining enforcement sufficiency — particularly when the debtor themselves has previously disclosed or relied on that property in connected proceedings. Second, courts have issued asset disclosure orders requiring debtors to provide documentary evidence of foreign property holdings, including title documents obtained from the UAE's registration authorities. Non-compliance with those orders has, in some instances, been treated as a factor adverse to the debtor in subsequent proceedings, though courts have stopped short of treating silence as conclusive proof of ownership.

The more contested question — whether a Russian court can directly order enforcement against UAE-situated real property — has produced less settled results. Several first-instance courts have declined to make such orders on the grounds that Russian civil procedure does not extend its enforcement jurisdiction to property outside Russian territory, at least in the absence of a bilateral treaty framework. Courts have generally pointed to the absence of a comprehensive legal assistance treaty between Russia and the UAE as the structural constraint. However, a minority of rulings has taken a materially different approach, reasoning that the court's power to impose an interim injunction freezing assets — including foreign assets — derives from broader procedural authority and is not limited by territorial jurisdiction in the same way as direct execution.

"These decisions reveal that Russian courts are beginning to engage seriously with the substance of foreign asset enforcement, even where the enforcement mechanisms remain structurally incomplete — and creditors who understand that distinction recover more effectively." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The practical significance of the interim injunction route should not be overstated. A Russian-issued freezing order over UAE property has no automatic effect in the UAE; its value lies in the risk it creates for the debtor — the prospect of parallel UAE proceedings recognising the Russian order — and in its evidentiary and reputational weight in any subsequent enforcement action commenced locally in the UAE.

For firms advising creditors with a Russian counterparty who may hold UAE real estate, confirming the current Russian procedural position before commencing enforcement is a material step — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign counsel instructing Russian lawyers on asset tracing and recovery matters, the emerging case law carries several practical takeaways that bear directly on how instructions are framed and how the recovery strategy is sequenced.

The first is evidentiary. Russian courts have demonstrated a readiness — albeit cautious — to receive and act on foreign property evidence. This means that the investigative phase, including the assembly of UAE land registry data, property valuation records, and transaction history, is worth completing before Russian proceedings are commenced rather than during them. Counsel who arrive at a Russian disclosure application with well-organised foreign property documentation will typically encounter a more receptive court than those seeking to build the evidential case through the proceedings themselves.

The second is strategic sequencing. The cases reviewed suggest that the most productive approach combines a Russian enforcement or interim relief application — to create the procedural record and any available freezing relief — with parallel action in the UAE, coordinated with local Emirati counsel. The Russian court record, particularly a disclosure order, strengthens the UAE application by establishing the debtor's acknowledgement or the court's independent finding that the property exists and is beneficially connected to the debtor.

The third concerns the value of early Russian counsel involvement. Firms considering this route will benefit from engaging Russian lawyers before the UAE strategy is finalised, since the Russian procedural steps — disclosure orders, enforcement applications, interim relief — each have timing dependencies that affect the overall sequencing. The firm's Asset Tracing & Recovery practice has acted for foreign creditors navigating exactly this type of cross-jurisdictional enforcement challenge.

For a more detailed analysis of the regulatory background to UAE property held by Russian nationals, see Regulatory update: UAE real estate owned by Russian nationals and the client briefing at Foreign creditors and UAE real estate owned by Russian nationals. For creditors with related cross-border dispute proceedings, the firm's Cross-Border Disputes practice operates alongside the asset recovery team. A selection of representative matters is available at /matters/.

• Regulatory update: UAE real estate owned by Russian nationals
• Foreign creditors and UAE real estate owned by Russian nationals — a practical briefing
• Asset Tracing & Recovery — practice overview

Q: What does this ruling change for foreign creditors pursuing Russian nationals with UAE assets?

A: Recent Russian court decisions confirm that courts of general jurisdiction are willing to engage with UAE real property as part of the debtor's asset picture — issuing disclosure orders, and in some cases interim freezing relief, in respect of property situated outside Russia. For foreign creditors, the most immediate practical change is that the Russian enforcement stage is no longer a dead end when domestic assets appear insufficient. The cases also clarify, however, that direct execution against UAE property remains structurally unavailable through Russian procedure alone; the value of the Russian proceedings lies in building the evidentiary and procedural foundation for parallel UAE enforcement. Creditors who understand and exploit that combination consistently achieve better recovery outcomes than those who treat the two jurisdictions as independent tracks.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors and their advisers should treat the Russian procedural stage as an active component of the overall recovery strategy rather than a preliminary hurdle. Practically, this means instructing Russian counsel early — before the UAE strategy is finalised — to assess whether a disclosure order or interim freezing application is available on the specific facts, and to assemble the foreign property documentation needed to support that application. Firms coordinating cross-border recovery should ensure that their Russian and UAE counsel teams are working to a shared sequencing plan, since the timing of Russian procedural steps affects the strength of the subsequent UAE application. Where the debtor is a Russian national who retains connections to the Russian legal system, the Russian proceedings carry leverage that is frequently underutilised.

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

The firm's Asset Tracing & Recovery practice advises foreign creditors, litigation funders, and foreign law firms instructing local Russian counsel on asset identification, disclosure proceedings, and cross-border enforcement strategies targeting Russian-connected debtors. With over 1,000 matters handled since inception, the team provides direct partner involvement on every engagement, offering the procedural depth and cross-border coordination experience that complex recovery mandates require.

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

If you are coordinating enforcement action involving Russian nationals with UAE property interests — discuss your matter with our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

In recent practice advising foreign creditors on multi-jurisdictional recovery, one question arises with increasing frequency: when enforcement steps are being pursued simultaneously in Russia and abroad, which procedural sequence governs, and what happens when a Russian court disagrees with the approach taken by counsel in a parallel forum? A recent appellate reversal in a Russian arbitrazh court has given that question a concrete and materially significant answer — one that alters the practical calculus for foreign law firms instructing Russian lawyers and for claimants managing coordinated enforcement campaigns across Russia and foreign jurisdictions.

The matter arose from a multi-jurisdictional enforcement effort initiated by a foreign trade creditor seeking recovery against a Russian counterparty with assets distributed across Russia and at least one European jurisdiction. The claimant's strategy involved commencing Russian enforcement proceedings in parallel with steps in the foreign forum, with both sets of proceedings directed at securing and realising assets. At first instance, the Russian arbitrazh court accepted jurisdiction over the domestic enforcement application and proceeded to consider the request in isolation from the foreign proceedings — treating the Russian enforcement track as a self-contained matter.

The appellate stage introduced a different analytical framework. The appellate court reversed the first-instance approach and held, in substance, that the sequencing and scope of the Russian enforcement steps could not be evaluated without reference to the claimant's position in the parallel proceedings. The court's concern, as it emerges from the reasoning, was the risk of double recovery or procedural inconsistency — a concern that sits at the intersection of Russian civil procedure and international comity principles that Russian courts have applied inconsistently across circuits.

This was not the first time a Russian appellate body had intervened on coordination grounds, but the framing of the reversal — specifically, the weight placed on the claimant's posture in the foreign proceedings — represents a meaningful development in how Russian courts assess multi-jurisdictional asset recovery strategies. For firms coordinating enforcement across Russia and foreign jurisdictions, the implications deserve careful attention.

The appellate court's central holding was that a claimant pursuing enforcement in Russia cannot be treated as an isolated domestic applicant when that claimant has simultaneously initiated, or is actively maintaining, enforcement proceedings directed at the same debtor in a foreign jurisdiction. The court reasoned that the aggregate relief sought must be viewed as a single recovery effort, and that Russian enforcement measures — including any asset freeze or realisation order — must be proportionate to the outstanding balance after accounting for steps taken elsewhere.

This proportionality framing is the technically significant element of the ruling. Russian courts have long applied proportionality analysis within domestic proceedings, but extending it to require consideration of a foreign enforcement posture introduces a coordination obligation that Russian procedural law does not articulate in express terms. The appellate court drew this obligation from general civil procedure principles rather than from any specific provision on international parallel proceedings, which leaves the scope of the ruling open to further development at the cassation stage.

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The court also commented, in passing, on the quality of the evidentiary record presented at first instance regarding the foreign proceedings. The record had not adequately documented the current status and extent of enforcement steps abroad. This evidential gap materially undermined the first-instance court's ability to assess proportionality — and the appellate court treated this as a structural failing rather than a correctable procedural deficiency.

For foreign law firms managing parallel enforcement tracks involving Russia, early guidance on evidentiary and sequencing requirements is the practical priority. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The immediate practical consequence of this ruling is that any foreign creditor pursuing enforcement across Russia and one or more foreign jurisdictions should assume that a Russian appellate court may examine the totality of the recovery effort — not merely the domestic enforcement application before it. That assumption changes the document architecture, the sequencing logic, and the briefing provided to Russian counsel from the outset.

For firms instructing Russian lawyers in these matters, three procedural adjustments are worth considering. First, the evidentiary record filed in Russian proceedings should include contemporaneous documentation of the status of all parallel enforcement tracks — including steps that have not yet produced results. Second, the relief sought in Russia should be calculated with reference to the outstanding balance, explicitly accounting for any amounts secured or anticipated in the foreign proceedings. Third, coordination communications between Russian and foreign counsel should be documented in a form that can be presented to the Russian court if required — a step that many cross-border enforcement teams have not historically prioritised.

The ruling does not close the door on simultaneous enforcement in multiple jurisdictions. Russian law does not prohibit parallel proceedings, and the appellate court did not suggest otherwise. What the court requires is that the Russian enforcement steps be situated, evidentially and analytically, within the broader recovery picture. For claimants and their advisers, that is a structural adjustment to how coordinated enforcement campaigns are planned and resourced — not a fundamental reordering of strategy, but a material change in execution. Counsel at Vetrov & Partners regularly coordinate with foreign law firms on asset tracing and recovery matters involving Russian-sited assets; the firm's Asset Tracing & Recovery practice routinely manages the Russian leg of multi-jurisdictional enforcement efforts where this coordination obligation applies. Related court practice developments are surveyed in Court practice shift on coordinating enforcement and key risk points are addressed in Key risk points in coordinating enforcement.

• Court practice shift on coordinating enforcement across Russia
• Key risk points in coordinating enforcement across jurisdictions
• Asset tracing and recovery in Russia
• Representative matters — asset recovery

Q: What does this ruling change?

A: The ruling changes the evidentiary and analytical framework that Russian appellate courts apply when a claimant is pursuing enforcement in Russia alongside proceedings in a foreign jurisdiction. Previously, Russian first-instance courts routinely assessed domestic enforcement applications in isolation. The appellate decision establishes — at least at the circuit level — that the Russian enforcement steps must be proportionate to the outstanding balance across all proceedings, and that the Russian court record must document the status of the foreign enforcement track. Claimants and their counsel who do not address this in the Russian filing risk appellate challenge on the same grounds that succeeded here.

Q: What should foreign companies do in light of this decision?

A: Foreign claimants and the foreign law firms instructing Russian counsel on enforcement matters should review their briefing and evidentiary practice for Russian proceedings. The immediate priority is to ensure that the Russian enforcement record documents the current position in all parallel proceedings and that the relief sought in Russia is calculated with the global recovery picture in mind. For matters already in progress, this may require supplementary filing. For matters at the planning stage, the sequencing and documentation framework should be built with this coordination obligation in view from the start. Counsel experienced in both Russian procedure and cross-border enforcement coordination — particularly local counsel Russia who regularly work with foreign instructing firms — are best placed to advise on how to structure the record.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years and 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 the Russian leg of multi-jurisdictional enforcement and recovery strategies. The team regularly manages Russian asset freeze applications, enforcement proceedings before Russian arbitrazh courts, and the coordination of Russian steps with parallel proceedings in European and other jurisdictions. With over 1,000 matters handled, the practice combines deep procedural knowledge of the Russian enforcement process with direct partner involvement at every stage.

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

Discuss your enforcement matter in confidence — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

For foreign law firms advising claimants who hold worldwide freezing orders issued by English or other common law courts, the question of whether and how those orders reach Russian-situated assets has long been one of the more awkward gaps in cross-border enforcement practice. Russian courts do not recognise foreign interim measures as directly enforceable instruments, and the route to protecting assets in Russia has historically required a parallel application under the domestic provisional measures regime. A recent clarificatory development from the Russian Supreme Court addresses this gap in a way that has material consequences for how foreign counsel should frame their instructions to Russian local counsel, and for the sequencing of multi-jurisdictional freezing strategies when Russian assets are in scope.

The question before the court arose in circumstances that will be familiar to any practitioner who has acted on the creditor side of a cross-border dispute with a Russian dimension. A foreign claimant, having obtained interim relief in offshore proceedings, sought to give practical effect to that relief in Russia by applying to an arbitrazh court for provisional measures over assets held by the Russian respondent. The arbitrazh court at first instance declined to grant parallel interim measures, on the basis that the foreign order already addressed the assets in question and that a domestic measure was therefore redundant. On review, the position was contested: the respondent argued that the foreign order had no operative effect in Russia and that the domestic application was procedurally deficient; the claimant argued that Russian procedural law permitted, and in the circumstances required, a domestic measure to be granted independently of the foreign proceeding. The matter ultimately reached the Supreme Court on a point of principle concerning the relationship between foreign interim relief and Russia's domestic provisional measures framework under the arbitrazh procedural rules.

The Supreme Court's clarification proceeds from a foundational premise: a worldwide freezing order issued by a foreign court does not, as a matter of Russian procedural law, create any directly enforceable obligation in respect of assets situated in Russia. The order binds the respondent personally, but Russian courts and third parties holding Russian-situated assets are not bound by its terms absent a domestic enforcement mechanism. This, in itself, is not new. What the ruling adds is a clear statement that the existence of a foreign worldwide freezing order does not preclude, and in appropriate circumstances affirmatively supports, a parallel application for provisional measures before a Russian arbitrazh court. The court held that the domestic application should be assessed on its own merits under Russian procedural standards, and that a foreign order may be placed before the Russian court as evidence of urgency and of the claimant's substantive position, without requiring that the foreign proceedings be the seat of the underlying dispute.

"This ruling closes an interpretive gap that Russian arbitrazh courts have handled inconsistently: foreign counsel can now present their offshore freezing order as a relevant supporting document in a Russian provisional measures application without that order being treated as either redundant or inadmissible." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

The court also addressed a procedural point with practical significance: the timing of the Russian application. The ruling indicates that a domestic provisional measures application should, wherever practicable, be made contemporaneously with or immediately following the grant of foreign interim relief, rather than after a delay during which assets may have been dissipated. This is consistent with the general urgency requirement under Russia's arbitrazh procedural rules, but the Supreme Court's articulation of the principle in the context of cross-border proceedings gives lower courts clearer authority to grant relief on an expedited basis where a foreign WFO is already in existence.

If you are advising a client who holds a worldwide freezing order and needs to secure Russian-situated assets, confirming your local counsel relationship before the application is made can be critical to the timing of relief. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The ruling has three practical implications for foreign firms with clients whose asset-tracing and recovery strategies include a Russian dimension.

First, the parallelism argument is now settled at the highest domestic level. Foreign counsel should not be deterred from advising a parallel Russian provisional measures application on the ground that a WFO is already in place. The two instruments operate on different legal bases and serve different enforcement functions: the foreign order binds the respondent; the Russian domestic measure binds Russian courts, third-party banks, and asset registries. Both are needed for effective protection of Russian-situated assets.

Second, the foreign WFO now has an evidential role in Russian proceedings that was previously contested. Practitioners instructing local counsel on Russian applications should include a certified translation of the foreign order in the materials submitted to the arbitrazh court, together with a brief note on its scope, the assets it covers, and the forum in which it was granted. Russian courts will assess urgency, and the existence of a foreign order from a recognised institutional forum carries weight in that assessment.

Third, the timing window matters. The Supreme Court's emphasis on contemporaneous or near-contemporaneous filing reinforces what experienced local counsel already know: a Russian provisional measures application filed weeks after a foreign WFO has been obtained is more vulnerable to challenge on urgency grounds than one filed promptly. Foreign counsel should build the Russian application into their initial enforcement timetable, not treat it as a fallback measure if asset dissipation is detected later. For firms seeking to appoint Asset Tracing & Recovery counsel in Russia as part of a wider enforcement strategy, the timing of that appointment is itself a substantive decision.

It is worth noting one area where the ruling does not fully resolve the landscape. The Supreme Court addressed the arbitrazh court context, which covers commercial and corporate disputes. Where assets are held in a structure that falls outside the arbitrazh courts' subject-matter jurisdiction, the procedural pathway may differ, and the implications of the ruling for general jurisdiction courts in that context remain to be worked through in lower-court practice. The firm's commentary on the broader landscape is set out in Worldwide Freezing Orders and Russian-Situated Assets and in the practical guide at A Practical Guide to Worldwide Freezing Orders Involving Russian Assets.

For foreign creditors who are assessing whether this development changes their recovery calculus, the key question is not whether the ruling creates new rights but whether it removes the procedural uncertainty that previously discouraged parallel domestic applications. The answer is that it substantially does.

To discuss how this ruling affects a live enforcement matter involving Russian-situated assets, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Worldwide Freezing Orders and Russian-Situated Assets
• A Practical Guide to Worldwide Freezing Orders Involving Russian Assets
• Asset Tracing and Recovery in Russia: An Overview for Foreign Creditors

Q: What does this ruling change for foreign firms holding worldwide freezing orders over Russian assets?

A: The ruling confirms, at the level of the Russian Supreme Court, that a worldwide freezing order granted by a foreign court does not preclude and actively supports a parallel provisional measures application before a Russian arbitrazh court. Before this clarification, lower courts took inconsistent positions on whether the domestic application was admissible where a foreign order already existed. The ruling resolves that inconsistency in favour of admissibility, and establishes that the foreign order may be submitted as evidence of urgency in the Russian proceedings. For foreign firms, this means that the domestic Russian application is no longer a question of whether to file but of when, and the answer on timing is: promptly, ideally contemporaneously with the foreign order.

Q: What should foreign companies and their counsel do in light of this decision?

A: Three actions follow from the ruling. First, review any live enforcement matters involving Russian-situated assets to assess whether a domestic provisional measures application has been made or remains available. Second, if instructing Russian local counsel for the first time, ensure that counsel is briefed on the foreign order, its scope, and the procedural history before making the domestic application. Third, build the Russian application into the initial enforcement timetable rather than treating it as a secondary step. Where the foreign order covers assets in multiple jurisdictions including Russia, the Russian domestic application should be coordinated with foreign counsel but filed under Russian procedural standards on an independent legal basis.

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

The firm's asset tracing and recovery practice advises foreign creditors, foreign law firms, and institutional claimants on provisional measures, enforcement proceedings, and multi-jurisdictional recovery strategies involving Russian-situated assets. The practice works closely with foreign counsel to coordinate domestic Russian applications with offshore enforcement steps, and has acted on creditor-side mandates across the Siberian and Ural federal districts. Enquiries welcome from firms seeking to appoint confirmed local counsel at the outset of an enforcement strategy.

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/

In a decision handed down in late 2025, a Russian commercial court addressed a question that had been mounting in creditor-side practice for several years: when a foreign party to Russian asset recovery proceedings operates under OFAC licensing constraints, does the existence of those constraints bear on the conduct — or the admissibility — of the Russian enforcement process itself? The court's answer, and its reasoning, have material consequences for foreign law firms instructing Russian counsel on cross-border recovery matters. This comment analyses what the court held, why the reasoning diverges from earlier circuit-level practice, and what the decision means for foreign parties currently engaged in — or contemplating — Russian asset recovery.

Asset recovery proceedings in Russia, when they involve a foreign creditor, have long carried a procedural complexity that goes beyond the purely Russian-law dimension. The Russian Commercial Procedure Code (the "Code") governs the proceedings themselves — including jurisdiction, service, evidence, and enforcement — and does not incorporate foreign regulatory constraints on a party's capacity to transact or receive funds. In practice, however, where the claimant or the assets involved attract restrictions imposed by a foreign regulatory authority, the question of how Russian courts should characterise that status has remained unsettled.

The matter under comment arose in the following circumstances. A foreign institutional creditor — operating under a general licence framework administered by a US regulatory body — sought to enforce a debt obligation against a Russian corporate counterparty. The assets available for recovery included receivables and moveable property held within the Russian Federation. Prior to the Russian proceedings, the creditor had obtained necessary authorisation under its licensing regime to conduct the enforcement activity. The Russian respondent, however, raised a procedural objection: it argued that the creditor's constrained status affected the validity of the enforcement steps taken, and that the court should treat the regulatory position as bearing on the creditor's standing to seek enforcement in a Russian forum.

The court at first instance dismissed the objection on narrow procedural grounds, without addressing the substantive question. On appeal, the appellate commercial court reached the same result, but did so on substantive grounds — holding that the regulatory position of a foreign party under a foreign licensing regime is a matter for that party's home jurisdiction and does not create a condition precedent to standing before a Russian commercial court. It was the appellate reasoning, rather than the outcome, that represents the development of note.

For foreign law firms managing asset recovery instructions with a Russian dimension — including where the client's regulatory position is a live issue — an early consultation with Russian counsel can prevent the procedural objection from becoming a substantive obstacle. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The appellate court's reasoning proceeded in three stages. First, it affirmed that the admissibility of a foreign party's claim before Russian commercial courts is determined exclusively by reference to Russian procedural law and the applicable international agreements — not by reference to the regulatory law of the claimant's home state. The court drew a clear line between the question of whether a party has legal capacity to litigate (a Russian-law question) and the question of whether a party has authorisation to transact under its home-state regulatory framework (a foreign-law question). The former falls within the court's jurisdiction; the latter does not.

Second, the court addressed the argument that the presence of OFAC-related constraints on the creditor's ability to receive funds should be treated as a condition on the enforceability of any recovery order. This argument — which had found some traction in earlier first-instance decisions in other circuits — was rejected. The court held that the enforceability of a judgment or enforcement order is assessed at the point of execution, not at the point of the court's issuance of the order. A party seeking enforcement bears the obligation to ensure that receipt of recovered funds is consistent with its applicable regulatory framework; the Russian court's role is to determine the legal entitlement, not to pre-assess the foreign regulatory consequences of satisfying it.

Third, and most significantly for forward-looking practice, the court noted that the creditor's prior authorisation under its licensing regime — while not a condition of standing — was a relevant procedural fact in the context of good faith. The court observed that a foreign party that actively obtains necessary authorisation before commencing proceedings demonstrates the kind of procedural good faith that Russian courts treat as relevant to the exercise of judicial discretion in enforcement matters. This third strand of the reasoning is not binding, but it has clear implications for how foreign creditors should position themselves before filing.

"The court's explicit separation of standing from regulatory capacity is the most significant development in this area of Russian commercial practice in recent years — it provides a cleaner procedural framework for foreign creditors whose status has previously been used as a lever by respondents seeking delay." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign law firms instructing Russian counsel on creditor-side mandates, the decision resolves one line of procedural risk while opening a set of practical considerations.

The resolved risk is the standing challenge. Prior to this decision, respondents in several first-instance matters had deployed the argument that a foreign creditor's constrained regulatory status created a defect in its capacity to bring or maintain Russian proceedings. That argument now faces a reasoned appellate precedent — at the circuit level — that squarely rejects it. Instructing firms should note, however, that first-instance courts in other circuits are not bound by this reasoning, and the position should be confirmed for each jurisdiction where assets are located.

The practical considerations that emerge from the third strand of the court's reasoning are more nuanced. The court's observation about prior authorisation and procedural good faith suggests that foreign creditors operating under a licensing framework would be well advised to have documented evidence of that authorisation position before commencing Russian proceedings — not as a legal prerequisite, but as a procedural asset. In practice, this means that the pre-litigation stage of a Russian asset recovery matter should now routinely include a regulatory clearance memo prepared in the foreign home jurisdiction, capable of being placed before the Russian court if the respondent raises the regulatory position as a substantive issue.

For firms at the stage of considering whether to instruct Russian counsel, the decision also clarifies something about the asymmetry of the enforcement process. The Russian court's role is limited to determining legal entitlement and issuing orders. The downstream question — whether the creditor can actually receive the recovered funds in compliance with its home-state regulatory obligations — remains entirely outside the Russian proceeding. Foreign instructing firms should ensure that their client has obtained a clear view of this downstream position before enforcement commences. Misalignment between the Russian enforcement timeline and the regulatory clearance timeline is a practical risk that local Russian counsel alone cannot resolve.

The firm's Asset Tracing & Recovery practice regularly acts on creditor-side mandates involving foreign parties with complex regulatory positions. For further background on how the Federal Tax Service's recent guidance intersects with this decision, see Federal Tax Service issues guidance on OFAC-related documentation in Russian enforcement proceedings and OFAC sanctions intersection with Russian asset recovery strategy: a practitioner's overview.

If your firm is managing a Russian asset recovery instruction where the client's regulatory position is a live consideration — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Federal Tax Service issues guidance on OFAC-related documentation in Russian enforcement proceedings
• OFAC sanctions intersection with Russian asset recovery strategy: a practitioner's overview
• Enforcing foreign creditor claims in Russian insolvency proceedings

Q: What does this Russian court decision change for foreign creditors pursuing asset recovery?

A: The decision establishes, at appellate level, that a foreign party's regulatory status under a foreign licensing regime is not a condition of standing before Russian commercial courts. Respondents have previously used arguments about creditor regulatory constraints to challenge the admissibility of proceedings; that line of argument now faces direct appellate authority rejecting it. The practical change is that foreign creditors can proceed to file in Russian proceedings with greater confidence that a standing challenge of this kind will not succeed at the appellate level, provided the underlying Russian procedural requirements are satisfied.

Q: What should foreign law firms instructing Russian counsel do differently in light of this ruling?

A: Two steps are advisable. First, ensure that the client has obtained and documented any necessary regulatory authorisation in its home jurisdiction before commencing Russian proceedings. The court's reasoning on procedural good faith suggests this documentation, while not legally required, strengthens the client's position if the regulatory status is raised. Second, confirm with Russian counsel that the specific circuit where the assets are located has not adopted a divergent first-instance approach — the appellate authority commented on here is from one circuit and is persuasive, not binding, in others. Instructing firms should also address the downstream question: whether the client can receive recovered funds in compliance with its regulatory framework is outside the Russian proceeding and must be addressed separately.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years and 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 creditor-side mandates before Russian commercial courts and in cross-border enforcement. The team acts as local Russian counsel on matters involving complex cross-jurisdictional creditor positions, and regularly coordinates with instructing foreign firms on procedural strategy and regulatory interface. With over 1,000 matters handled since inception, the practice combines procedural depth with direct partner-level 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/

Foreign litigators advising clients with Russian-nexus digital asset claims have, until recently, operated in near-total uncertainty about how Russian courts would treat cryptocurrency as a recoverable and traceable asset. A series of decisions issued by Russian state courts in the period leading to mid-2026 has begun to resolve that uncertainty — not comprehensively, but enough to alter the working assumptions that foreign counsel should bring to these instructions. The decisions address the threshold question of whether digital assets constitute property for the purposes of civil enforcement, the procedural mechanism for freeze orders over cryptocurrency wallets, and the evidentiary standards applied to blockchain forensics presented as tracing evidence. The answers are consequential for any firm instructing local counsel in Russia on a recovery matter involving digital assets.

The central legal question in this line of decisions concerns the civil characterisation of digital assets under Russian law. Russian civil legislation was amended to recognise digital rights — including digital financial assets and utility digital tokens — as objects of civil rights, placing them within the broader category of property for enforcement purposes. What the legislation left unresolved was the procedural question: how does a claimant actually freeze, identify, or recover a digital asset held in a wallet, and what standard of proof does a Russian court require before it will act on blockchain tracing evidence? These were the questions that a series of enforcement and asset recovery proceedings — most initiated by trade creditors or insolvency administrators seeking to trace funds transferred out of insolvent estates — placed before Russian arbitrazh courts and, ultimately, on appeal before the circuit courts. The matters involved respondent companies that had transferred value into cryptocurrency in the period preceding formal insolvency proceedings, with foreign creditors or their local counterparts seeking to recover that value as part of the broader estate.

The courts in these proceedings reached several conclusions that, taken together, constitute a meaningful shift in the Russian enforcement landscape for digital asset tracing and cryptocurrency recovery. First, Russian arbitrazh courts confirmed that digital financial assets held in identified wallets are capable of being subject to interim freeze orders under the civil procedure rules governing asset preservation. The courts treated wallet addresses — when supported by blockchain analysis linking them to the respondent — as sufficient identification of the asset for the purposes of an interim application. Second, the courts engaged substantively with blockchain forensics evidence for the first time in published decisions. Courts accepted expert reports produced by recognised blockchain analytics providers as admissible evidence, although the evidentiary weight given to that material varied between instances and circuits. The prevailing approach, as it emerges from the pattern of decisions, requires the tracing analysis to satisfy a chain-of-custody standard: the expert must demonstrate an unbroken analytical path from the respondent's known wallet to the target address. Third, where a Russian-domiciled exchange held the relevant assets, the courts issued disclosure and freezing orders directly against the exchange as a third-party holder — a procedural step that mirrors asset-freezing practice in other jurisdictions but had not previously been applied to digital assets in the Russian context. The position with respect to non-custodial wallets and foreign-domiciled exchanges remains substantially unsettled, and counsel should not assume that the same procedural tools are available in those circumstances.

"What these decisions establish is a workable entry point for digital asset tracing claims in Russian courts — but the procedural architecture is still forming, and the variation between circuits is material enough that choice of forum and timing of the freeze application remain critical tactical questions." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

If you are instructing Russian counsel on a matter involving digital asset recovery or a Russian court digital asset cryptocurrency ruling — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For law firms advising clients with Russian-nexus digital asset and cryptocurrency tracing claims, these decisions change the calculus in three respects. First, it is now viable — not merely theoretically arguable — to seek a Russian asset freeze over cryptocurrency wallets held at a Russian-registered exchange, provided the tracing analysis meets the chain-of-custody standard the courts have articulated. Firms instructing Russian lawyers on foreign firm instructions should factor in the quality and format of the blockchain forensics report from the outset: Russian courts have shown willingness to engage with this material, but they are not yet practised in evaluating it, which places a premium on expert reports that are structured for a non-specialist judicial audience. Second, the timing of the freeze application is critical. The decisions confirm that Russian courts will grant interim freeze orders on an ex parte basis where there is a credible risk of dissipation — but the window between the identification of the wallet address and the respondent becoming aware of the tracing activity is narrow. In at least one matter in which the firm acted for a foreign trade creditor in parallel enforcement proceedings, the value of early-stage blockchain analysis was in enabling a freeze application before the assets were moved to a non-custodial wallet. Third, firms should advise clients on the circuit-level variation that currently exists. The West Siberian circuit and the Moscow circuit have, in parallel, addressed digital asset tracing questions, but their approaches to the evidentiary standard are not yet fully harmonised. Local counsel selection and, where there is a choice, forum selection should take account of the emerging circuit jurisprudence. The position under the Asset Tracing & Recovery practice framework at the firm reflects this circuit-level mapping. For the broader analytical context, see also the firm's analysis of the Russian Supreme Court clarification on digital assets and the practical guide to digital asset and cryptocurrency tracing in Russia.

• Russian Supreme Court clarification on digital assets: what changed
• Navigating digital asset and cryptocurrency tracing in Russia: a practical guide
• Asset tracing and recovery in Russia: an overview for foreign counsel

Q: What does this ruling change?

A: The decisions confirm, for the first time in a consistent pattern, that Russian arbitrazh courts will treat digital financial assets as property capable of being frozen and recovered through civil enforcement procedure. Before this line of decisions, the civil characterisation of digital assets was acknowledged in legislation but had not been consistently applied at the procedural level. The practical change is that a creditor can now seek an interim freeze order over a cryptocurrency wallet held at a Russian-registered exchange — provided the tracing analysis satisfies the chain-of-custody standard the courts have adopted — and the courts will act on that application. The evidentiary framework for blockchain forensics evidence is still developing, and the position with respect to non-custodial wallets and foreign-domiciled exchanges remains uncertain, but the threshold question of whether digital assets are recoverable has been answered affirmatively.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors and the firms instructing Russian lawyers on their behalf should take three practical steps. First, ensure that any blockchain forensics analysis commissioned for a Russian-nexus matter is structured to meet the chain-of-custody standard the courts have described — this means the expert report should demonstrate an unbroken analytical path and be written for a judicial audience unfamiliar with blockchain methodology. Second, consider the timing of any freeze application carefully: the window between identification of the target wallet and potential dissipation of assets is narrow, and the procedural route to an ex parte order is now established. Third, verify that local counsel has experience with the circuit-level variation in how different Russian courts are approaching digital asset tracing evidence, as the approach is not yet uniform across jurisdictions. Early engagement with Russian counsel on the forensics preparation — before litigation is formally commenced — is likely to be determinative.

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 and recovery practice advises foreign creditors, insolvency practitioners, and the law firms instructing them on tracing and enforcement matters in Russian state courts. With over 1,000 matters handled since inception, the team combines substantive knowledge of Russian civil enforcement procedure with direct partner and senior-lawyer involvement on every engagement. The firm works in English and provides English-language court documents and case updates as a matter of course.

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

If your firm is advising a client with a Russian-nexus digital asset or cryptocurrency recovery claim — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

In the course of advising foreign law firms on Russian asset-tracing and recovery matters, a question that recurs with notable frequency concerns the reach of beneficial ownership disclosure obligations: how far do Russian courts interpret them, and what standard of proof applies when a party contests another's claimed ownership structure? A decision handed down by a Russian arbitrazh court in late 2026 provides the clearest judicial statement on these questions to date, and its practical implications for foreign firms whose clients hold Russian assets — directly or through offshore intermediaries — deserve close attention.

The proceedings arose from a commercial dispute in which one party challenged the standing of its counterparty to assert a contractual claim, on the basis that the counterparty had failed to make the disclosures required under Russian anti-money laundering legislation and Russian corporate legislation governing beneficial ownership registers. The legal question was narrow but consequential: does a failure to comply with statutory beneficial ownership disclosure obligations affect the legal capacity of a company to pursue claims before an arbitrazh court, and what standard must a challenging party meet to raise this as a procedural bar?

The beneficial ownership disclosure framework in Russia requires legal entities to identify, verify, and record their beneficial owners — defined, broadly, as individuals who ultimately own or control the entity through a chain of participation of more than twenty-five percent, or who otherwise exercise effective control. The framework draws on obligations derived from Russian anti-money laundering legislation and is reinforced by regulatory guidance from Rosfinmonitoring, the financial intelligence unit. Where entities have foreign shareholders or intermediate holding structures, the obligation to "look through" to the ultimate natural person beneficiary has always been present in the statute; what has been less settled is how courts respond to contested or incomplete disclosure, particularly in adversarial proceedings.

The respondent, a company with a multi-tier ownership chain involving offshore intermediate entities, had filed the required disclosures, but the information provided in its register did not, in the claimant's submission, reflect the actual beneficial ownership position. The claimant argued that this rendered the respondent's claim inadmissible; the respondent maintained that its disclosed structure was accurate and that the applicable legislative standard had been satisfied. The case thus required the court to address not only the definition of beneficial ownership under Russian law, but also the evidentiary threshold for challenging a counterparty's disclosure and the procedural consequences of a finding of non-compliance.

For foreign law firms instructing Russian counsel on asset-tracing or cross-border recovery matters — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The court declined to treat the alleged disclosure deficiency as a procedural bar to the respondent's claim. In doing so, it articulated a substantive principle: the beneficial ownership disclosure regime is an administrative compliance obligation, enforceable through regulatory and administrative channels, but it does not, in the ordinary course, affect a company's legal capacity or standing to litigate before the arbitrazh courts. The court reasoned that conflating regulatory compliance obligations with procedural standing would allow a challenging party to weaponise administrative disclosure gaps as a tactical device to delay or defeat substantively meritorious claims — an outcome inconsistent with the purposes of the anti-money laundering regime.

The court went further. Where a party challenges the accuracy of an opposing party's beneficial ownership disclosure, it bears the burden of adducing evidence that the disclosed structure does not reflect the actual control position — assertion alone does not suffice. The court set a materially higher threshold than the challenging party had anticipated: documentary evidence, forensic financial analysis, or equivalent probative material is required to shift the analysis from assertion to active judicial scrutiny. Circumstantial indicators — such as the presence of nominal directors, offshore holding vehicles, or prior regulatory correspondence — may form part of the evidentiary picture, but they do not independently establish a disclosure failure of the kind that would engage the court's intervention.

"This ruling establishes an important evidentiary threshold: where a party seeks to challenge a counterparty's beneficial ownership disclosure in Russian court proceedings, bare allegation is plainly insufficient — the challenger must produce substantive documentary evidence of the actual control position." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The court also addressed the treatment of offshore intermediate entities. It confirmed that the presence of offshore holding layers does not, of itself, indicate a beneficial ownership disclosure deficiency, provided the disclosures filed with the relevant register identify the ultimate natural person beneficiaries at each layer. This is a signal to advisers: the quality of the disclosure in the register, rather than the complexity of the ownership structure, is the measure the court will apply.

For foreign law firms advising clients with Russian assets or counterparties, this decision has implications across two distinct situations.

The first is defensive: clients who hold Russian assets through multi-tier offshore structures should review whether their beneficial ownership register filings accurately reflect the ultimate beneficial owner position as defined under Russian anti-money laundering legislation. The decision confirms that the administrative regime remains fully operative — the court's refusal to treat disclosure gaps as a procedural bar does not diminish the regulatory exposure for non-compliant entities. Rosfinmonitoring retains enforcement powers, and a finding of non-compliance in an administrative context can and does inform parallel judicial proceedings, particularly in insolvency and asset-recovery matters.

The second implication is offensive, and is perhaps more immediately relevant for foreign law firms instructing Russian counsel on asset-tracing mandates. The evidentiary threshold the court has set for challenging beneficial ownership disclosures is demanding, but it is not insuperable. Where a creditor or recovery claimant believes that a counterparty's disclosed beneficial owner position is inaccurate — for instance, because publicly available corporate records, ownership registers in other jurisdictions, or forensic financial analysis point to a different control position — the court's approach indicates a clear pathway: assemble the documentary evidence, file it in support of the challenge, and make the argument on the merits. The ruling from offshore structure alone is no longer available as a tactical shortcut. See also our analysis of the relevant legislative framework in Legislative amendments affecting beneficial ownership obligations in Russia and our practice guide on Beneficial ownership disclosure obligations under Russian law.

For firms co-ordinating multi-jurisdictional asset-tracing work that touches Russian assets, the practical priority is ensuring that the Russian-law component of the evidentiary picture — ownership register filings, corporate database extracts, regulatory correspondence — is developed in parallel with the foreign-jurisdiction record. Russian counsel can obtain certified extracts from relevant registers and assist in assessing the quality of any beneficial ownership disclosure against the statutory standard as interpreted by this ruling. Vetrov & Partners' asset tracing and recovery practice supports foreign firms at precisely this stage of the mandate. We also maintain a record of representative cross-border recovery mandates on our matters page.

If you are co-ordinating an asset-tracing matter involving Russian-held assets or a counterparty with a Russian ownership structure — speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Legislative amendments affecting beneficial ownership obligations in Russia
• Beneficial ownership disclosure obligations under Russian law
• Asset tracing and recovery in Russian insolvency proceedings

Q: What does this ruling change?

A: Prior to this decision, the evidentiary and procedural consequences of a beneficial ownership disclosure dispute in Russian arbitrazh proceedings were not clearly settled. The ruling establishes two things with precision: first, that non-compliance with beneficial ownership disclosure obligations does not, as a general rule, constitute a procedural bar to pursuing claims before the arbitrazh courts; and second, that a party wishing to challenge a counterparty's disclosed beneficial ownership position must adduce substantive documentary evidence — not merely raise an assertion. This clarifies the tactical landscape for both creditors seeking to trace assets through complex ownership structures and companies defending against such challenges.

Q: What should foreign companies do in light of this decision?

A: Foreign companies and their advisers should take two immediate steps. First, review the accuracy of any beneficial ownership register filings made in relation to Russian entities in which the foreign company holds an interest — the administrative regime remains fully enforceable regardless of this ruling, and incomplete or inaccurate filings carry regulatory exposure with Rosfinmonitoring. Second, where the foreign company is pursuing asset recovery against a Russian counterparty whose disclosed ownership structure is believed to be inaccurate, instruct Russian counsel to assess what documentary evidence is available to support a challenge: corporate register extracts, cross-border ownership records, and financial analysis are the building blocks the court will require.

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 and recovery practice advises foreign creditors, foreign law firms, and international litigants on the identification, preservation, and recovery of assets held in Russia, including through complex multi-tier ownership structures. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of Russian arbitrazh proceedings with direct partner involvement on every engagement. Foreign law firms are invited to make initial contact by email or messaging to establish whether a matter is within our scope.

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/

Practitioners advising foreign creditors on Russian asset-tracing work will recognise the pattern: a debtor's significant assets are held through a web of nominee arrangements, the debtor becomes insolvent or judgment-proof, and the creditor's claim evaporates on contact with a clean register. A recent cassation-level ruling by a Russian commercial court has materially altered that landscape. The court confirmed the analytical framework for identifying and unwinding nominee arrangement risks Russia creditors routinely encounter, drawing on a convergence of civil law principles, insolvency challenge provisions, and procedural tools that Russian courts have refined over several years of contested recovery litigation. For foreign firms instructing Russian lawyers on creditor-side mandates, the implications are both practical and strategic.

Nominee arrangements have long been a feature of Russian commercial practice. Their use spans legitimate corporate structuring — where a formal titleholder holds an asset on behalf of a disclosed beneficial owner — through to arrangements designed to place assets beyond the reach of creditors and enforcement authorities. Russian law does not provide a single statutory definition of a nominee relationship; courts have instead developed the concept through successive applications of sham-transaction doctrine, the general prohibition on abuse of rights, and creditor-protection provisions embedded in Russian insolvency legislation.

The matter under review arose from proceedings initiated by a foreign trade creditor that had obtained a Russian court judgment against a corporate debtor. On seeking enforcement, the creditor discovered that the debtor's principal operating assets — real property and receivables — had been transferred to third parties in transactions completed before, but in proximity to, the debtor's financial difficulties. The transactions were documented as arm's-length sales at apparent market value. However, a pattern of continuing operational control, related-party financial flows, and the absence of genuine commercial rationale persuaded the creditor's counsel to challenge them. The case was contested across two lower court instances before reaching cassation review.

The core legal question presented to the cassation court was whether a formally documented transfer of assets, completed between parties with no overt legal relationship but with demonstrable coordination of conduct, could be treated as a nominee arrangement giving rise to unwinding rights in favour of the creditor. The answer, and the court's reasoning, is the focus of this note. Foreign firms advising on matters touching the Asset Tracing & Recovery practice will find the court's analytical approach a useful reference point.

The cassation court upheld the challenge, confirming that the transfers should be treated as shams and set aside. Its reasoning rested on three analytical pillars that, taken together, represent a coherent and demanding framework for identifying nominee arrangement risks under Russian law.

First, the court held that formal documentation of a transaction does not, of itself, establish its genuineness. Where the evidence discloses that the transferor retained de facto control over the transferred assets after the purported transfer date — demonstrated by continuing management instructions, the absence of any change in operational counterparty relationships, and the redirection of economic benefits to the transferor — the transaction may be characterised as a nominee arrangement regardless of its documentation form. This displaced the previous tendency of some lower courts to treat a registered title transfer as presumptively conclusive.

Second, the court addressed the evidential threshold for establishing coordination between transferor and transferee. It declined to require direct proof of an express nominee agreement; circumstantial evidence of coordinated conduct, particularly where the transferee is unable to provide a credible commercial account of the transaction, is sufficient to shift the burden of explanation. This aspect of the ruling is significant for creditors whose ability to obtain direct evidence of nominee arrangements is constrained by the limits of pre-trial disclosure in Russian civil procedure.

Third, the court confirmed that the appropriate remedy on unwinding is restitution of the specific asset to the debtor's estate, not a monetary substitute. This matters for foreign creditors pursuing asset tracing in Russia because it forecloses the argument that a nominee arrangement can be neutralised by a damages award against an impecunious debtor entity.

"This ruling consolidates a line of development that practitioners have observed at appellate level for some time — but cassation confirmation is a different order of authority, and its effect on first-instance decision-making will be direct and durable." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

If you are advising a foreign creditor on Russian asset-tracing or enforcement proceedings and need confirmed local counsel — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms instructing Russian lawyers on recovery mandates, this ruling has three direct consequences worth considering before the next engagement.

The first concerns the scope of pre-litigation investigation. Under the approach now confirmed at cassation level, the evidential building blocks for a nominee arrangement challenge — operational continuity post-transfer, unexplained financial flows, absence of genuine commercial rationale — are precisely the facts that asset-tracing work can establish before proceedings are issued. Foreign counsel who have historically treated the investigation phase as a due diligence exercise for settlement negotiations should now treat it as direct preparation for a legal challenge. The evidentiary standard the cassation court has endorsed is one that careful pre-litigation work can meet.

The second concerns timing. Nominee arrangement challenges in Russian insolvency proceedings are subject to statutory look-back periods under Russian insolvency legislation, and outside insolvency the general limitation framework applies. The practical implication is that creditors who delay initiating proceedings risk finding that transactions which would otherwise have been challengeable fall outside the available window. Foreign firms advising on matters where there is any indication of asset-stripping through nominee vehicles should treat limitation analysis as an early-stage priority, not a later refinement. The FAS Russia enforcement trend on nominee arrangements reported in our related analysis confirms that regulatory attention to these structures has intensified alongside judicial development.

The third concerns cross-jurisdictional coordination. Where a nominee arrangement involves assets or parties in other EAEU or CIS member states, the unwinding judgment obtained in Russia may need to be recognised and enforced in those jurisdictions. The procedural basis for that recognition varies, and the creditor's enforcement strategy should account for it from the outset. Firms operating across these jurisdictions will benefit from early coordination between local counsel in each relevant seat. Vetrov & Partners collaborates with trusted counsel in relevant jurisdictions for matters requiring local admission elsewhere — see §0.2 of our firm's disclosure.

For foreign law firms considering instructing Russian lawyers on nominee arrangement risks or related asset-tracing work — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• FAS Russia enforcement trend on nominee arrangements
• How Russian courts approach nominee arrangements
• Restructuring & Insolvency practice — Vetrov & Partners

Q: What does this ruling change?

A: Before this cassation decision, lower courts showed inconsistency on whether registered title transfers could be challenged as nominee arrangements without direct evidence of a nominee agreement. The ruling resolves that inconsistency in favour of creditors: formal documentation is not conclusive, circumstantial evidence of coordinated conduct and retained de facto control is sufficient to trigger a challenge, and the remedy on unwinding is restitution of the asset rather than a monetary substitute. For foreign creditors and the firms advising them, this is a material shift in the practical reach of asset-tracing work in Russia.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors and their advisers should take three steps. First, review any pending or prospective Russian enforcement matter to identify whether asset transfers by the debtor are potentially challengeable under the framework the cassation court has confirmed. Second, instruct Russian local counsel to conduct a targeted limitation analysis before any investigative phase begins — the available challenge window is time-sensitive. Third, where the debtor's assets or counterparties span multiple EAEU or CIS jurisdictions, map the recognition-and-enforcement pathway in each jurisdiction as part of the initial strategy, not as a downstream task. Early engagement with experienced Russian lawyers on the nominee arrangement risks analysis is the most effective use of the time that this ruling now creates.

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 seeking local counsel on tracing and recovering assets held through Russian entities. The practice covers pre-litigation investigation, challenge proceedings in Russian commercial courts, and cross-border co-ordination with counsel in EAEU and CIS member states. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of the Russian cassation court system with 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/

In advising foreign creditors on cross-border asset recovery matters in Russia, one recurring pattern stands out: the legal standard for challenging a debtor's asset disposals has been developing quietly but materially in recent Russian court practice. Fraudulent transfer analysis under Russian civil law — the assessment of whether a transaction should be set aside because it was designed to defeat creditor claims — has historically attracted less systematic judicial attention than its equivalents in Western European insolvency or common law jurisdictions. A series of decisions in the Russian arbitrazh courts and the cassation circuit, handed down over the past several years, has changed that. Foreign law firms instructing Russian counsel on asset tracing and recovery mandates need to understand the direction of travel.

Russian civil law has long recognised the concept of a transaction that is voidable on grounds of bad faith or injury to creditors. The legal basis draws on general civil law provisions governing the validity of transactions, the doctrine of acting in good faith, and — in insolvency-related matters — the specific avoidance powers available to an insolvency administrator. Outside formal insolvency proceedings, the primary route is the creditor's claim to set aside a transaction that was structured, in substance, to remove assets from the debtor's estate before a claim crystallised or enforcement commenced.

The challenge, in practice, has been evidentiary. Russian courts have historically required a claimant to demonstrate both the debtor's subjective intent to harm creditors and the counterparty's awareness of that intent — a dual threshold that has proven difficult to satisfy when transactions are structured through intermediary entities or presented as commercially ordinary disposals at arms' length. This evidential burden has, until recently, placed asset recovery claimants in a structurally disadvantaged position, particularly when the transferee is a related party that has been careful to document the transaction with nominal formality.

The cases now emerging from the cassation circuit reflect a measurable shift in how courts are approaching this dual threshold — both at the stage of establishing intent and in the treatment of circumstantial evidence.

In a line of decisions considered by Russian arbitrazh courts at first instance and confirmed on cassation review, courts have moved towards a more structured, multi-factor analytical approach to fraudulent transfer analysis. Rather than requiring direct proof of the debtor's subjective intention to harm creditors, courts have shown a greater willingness to infer such intent from the aggregate of objective circumstances surrounding the transaction.

The factors courts have applied — drawn from the general framework for assessing bad-faith conduct under Russian civil law — include the proximity in time between the transaction and the commencement of creditor proceedings or the accrual of a significant debt obligation; the relationship between the transferor and transferee, with related-party transactions scrutinised more closely regardless of formal corporate separation; the price at which the asset changed hands relative to its assessed market value; and the post-transfer conduct of the transferor, including continued use or economic benefit from the asset purportedly disposed of.

Critically, courts have also addressed the treatment of the counterparty's knowledge. In several of the decisions reviewed, courts held that a transferee who is a related party, or who received the asset at a material undervalue, is presumed to have had constructive awareness of the debtor's financial position and the likely effect on creditors — placing the burden of rebuttal on the transferee rather than requiring the claimant to establish positive knowledge. This represents a structural advantage for recovery claimants and aligns the Russian analytical framework more closely with the presumptions familiar to practitioners in civil law jurisdictions across the EU.

"What these rulings signal is a judicial recognition that formalistic transaction documentation cannot substitute for a substantive analysis of economic reality — a standard that will have direct consequences for how asset disposal strategies are structured and challenged in Russia." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

One further development is notable: courts have, in several instances, upheld interim asset preservation orders — effectively a Russian asset freeze — at an early stage of proceedings, where the claimant presented a credible prima facie case of fraudulent transfer. The availability of interim relief alongside the substantive claim meaningfully changes the tactical landscape, enabling a creditor to ring-fence assets pending a full hearing rather than pursuing enforcement only after a final judgment has been obtained.

For foreign law firms advising clients with exposure to Russian counterparties, this judicial direction reinforces the value of early-stage engagement with Russian counsel to assess both the merits of a potential challenge and the prospects of interim protection.

For foreign firms advising on cross-border recovery matters with a Russian dimension, early assessment of the fraudulent transfer landscape is often determinative. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical implications of this developing case law are significant for three categories of instruction that foreign law firms commonly bring to Russian counsel.

First, for firms advising foreign creditors seeking to trace and recover assets that a Russian debtor has moved prior to enforcement, the multi-factor analytical framework now applied by Russian courts provides a more structured route to setting aside those transactions than was available under the earlier, intent-focused approach. A creditor that can demonstrate a pattern of disposal at undervalue to related parties in the period leading up to enforcement — without needing to prove subjective fraudulent intent — is in a materially stronger position than the previous standard suggested.

Second, for firms advising on the structuring of enforcement strategy, the availability of interim asset preservation alongside the substantive challenge means that the sequencing of proceedings matters. A well-framed application for interim relief, filed concurrently with or shortly after the main claim, may be capable of arresting further dissipation while the merits are heard. This is a tactical point that practitioners familiar with English freezing orders or German Arrest proceedings will recognise, though the Russian procedural route is distinct and requires separate analysis by local counsel Russia.

Third, for firms instructing Russian lawyers on behalf of respondents or transferees in these proceedings, the shift in the burden of proof on the knowledge question is a significant litigation risk. A client who received an asset from a related party at a discount, even if commercially rationalised at the time, should be advised to audit its position in light of this judicial direction before proceedings are initiated against it.

The decisions also carry implications for due diligence in M&A and structured finance transactions involving Russian assets. An acquirer of assets from a Russian entity under financial pressure — or from a holding structure where the underlying debtor relationship is not immediately apparent — may face a fraudulent transfer challenge from creditors of the original transferor. This is a point that should be expressly addressed in transaction-level advice where Russian assets form part of the consideration.

Firms instructing Russian counsel on these matters will find that the Vetrov & Partners Asset Tracing & Recovery practice is structured for precisely this type of cross-border coordination. The firm has acted in creditor-side recovery matters before Russian arbitrazh courts across the Siberian and Ural federal districts, and brings experience of managing the procedural sequencing — from interim applications through to enforcement of final orders — that these mandates require.

If you are advising a foreign creditor or respondent on a matter with a Russian fraudulent transfer dimension, we are available for an initial discussion. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Fraudulent Transfer Analysis Under Russian Civil Law: Regulatory Update
• Foreign Creditors and Fraudulent Transfer Analysis in Russia
• Asset Tracing & Recovery in Russia: Practice Overview

Q: What does this ruling change? A: The most significant change is methodological. Russian arbitrazh courts are now applying a structured, multi-factor test to fraudulent transfer claims rather than requiring direct proof of the debtor's subjective intent to harm creditors. Courts infer intent from objective circumstances — the timing of the disposal relative to creditor proceedings, the relationship between transferor and transferee, the transaction price relative to market value, and the transferor's post-disposal conduct. For related-party transactions and disposals at undervalue, courts are increasingly treating the transferee's knowledge of the debtor's financial position as presumed rather than requiring the claimant to establish it affirmatively. This shift in the burden of proof meaningfully improves the position of recovery claimants.

Q: What should foreign companies do in light of this decision? A: Foreign creditors with unsatisfied claims against Russian counterparties should assess, with Russian counsel, whether any pre-enforcement asset disposals by the debtor are susceptible to challenge under the developing judicial framework. The analysis is fact-specific: the timing, parties, price, and subsequent conduct around each disposal all bear on the merits. Where a credible case exists, the procedural option of seeking interim asset preservation — a Russian asset freeze — alongside the substantive challenge should be evaluated at the outset, since assets can continue to be moved during the pendency of proceedings. For firms on the respondent side, an audit of related-party transactions involving Russian assets — particularly those executed during a period of financial pressure on the transferor — is advisable before proceedings are initiated. In either case, instructing Russian lawyers with direct arbitrazh court experience at an early stage is the practical priority.

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

The firm's Asset Tracing & Recovery practice advises foreign creditors, distressed investors, and the foreign law firms instructing them on the full cycle of Russian recovery work: from pre-enforcement asset analysis and fraudulent transfer challenges through to the enforcement of Russian court orders and the coordination of multi-jurisdictional recovery strategies. Partner-direct involvement is standard on every engagement, and the firm's Novosibirsk base provides cost-effective access to proceedings across the Siberian and Ural federal districts without the overhead structure of Moscow practice.

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/

In the course of advising foreign law firms on Russian enforcement mandates, a recurrent assumption surfaces: that an interim relief order obtained at first instance provides a stable foundation on which to build a recovery strategy. A recent appellate decision in Russia has tested that assumption directly, and the outcome carries material consequences for foreign claimants and for the firms instructing Russian lawyers on their behalf. The appellate court reversed an interim relief order that had frozen assets linked to an offshore holding structure, finding that the evidentiary threshold for demonstrating a real risk of dissipation had not been met to the standard required at the appellate level. For instructing counsel, the ruling repays careful analysis.

If you are currently instructing Russian lawyers on an interim relief application or reviewing an existing order — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The proceedings concerned a commercial dispute in which a foreign claimant sought to freeze assets held through an offshore vehicle with connections to Russia. At first instance, the Russian court granted the interim relief application on the basis of a broadly framed submission that the respondent's corporate structure created a risk of dissipation, supported by documentary evidence of asset movements. The first-instance decision appeared, on its face, to reflect the prevailing approach in Russian court practice: courts at that level have generally shown a degree of procedural generosity when a claimant's substantive claim is adequately supported. The appellate court took a materially different view. It did not dispute the underlying merits of the claimant's case. Instead, it focused on the evidentiary quality of the dissipation risk analysis. The appellate panel found that the documentary record established historical asset movements but did not, in the court's assessment, demonstrate a prospective and imminent risk of dissipation of a kind sufficient to justify the continued restraint of assets. The interim relief order was discharged. The decision is consistent with a discernible pattern in Russian appellate courts: a narrowing of the evidentiary standard that will sustain an interim order on appeal, particularly where offshore structures are involved.

The appellate court's reasoning rested on a distinction that practitioners advising foreign claimants in Russia will need to internalise. Evidence that an asset has moved, or that a corporate structure is capable of moving assets, does not automatically satisfy the prospective risk standard that appellate panels apply when reviewing interim relief in Russian courts. The court required positive evidence of a concrete and near-term intention to dissipate, or of specific triggering conditions that would cause dissipation in the event the interim order were lifted. This is a demanding standard, and it is one that first-instance courts have not consistently required. The consequence of that inconsistency is now visible: a class of interim relief orders that survive at first instance will be vulnerable on appeal, and foreign claimants who have structured their enforcement strategy around a first-instance order may find themselves without the protective mechanism they believed was in place. The court also commented, briefly, on the adequacy of the undertaking as to damages provided by the claimant. This element of the reasoning is less developed in the decision than the evidentiary point, but it signals that appellate panels are prepared to look beyond the threshold question of whether interim relief was justified and to examine the procedural preconditions that must accompany any such order. For firms instructing Russian lawyers on behalf of creditor clients, this aspect of the ruling warrants attention when drafting the application package.

"The appellate reversal here reflects a maturing standard: Russian courts are increasingly treating interim relief as a measure requiring prospective, not merely historical, evidence of dissipation risk — a distinction that shapes how applications must be framed from the outset." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

Firms advising foreign creditors with Russian-connected assets should review whether existing interim relief orders meet the appellate evidentiary standard — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms instructing local counsel Russia on asset tracing and recovery matters, the practical implications of this ruling fall into three areas. First, application design: the evidentiary package supporting an interim relief application in Russia should be built, from the outset, to withstand appellate scrutiny — not merely to satisfy the more accommodating first-instance threshold. This means the prospective dissipation risk analysis must be anchored to specific, contemporaneous evidence rather than to structural inference alone. Second, strategic sequencing: where interim relief is a load-bearing element of the enforcement strategy — as it typically is in matters involving offshore assets with Russian connections — the risk of appellate discharge should be priced into the strategy at the instruction stage. Contingency planning that assumes the order will survive appeal in all cases is, in the light of this Russia ruling for foreign parties, no longer adequate. Third, the undertaking as to damages: the appellate court's observations on this point suggest that Russian courts may apply closer scrutiny to the form and substance of the undertaking, including whether it is backed by identifiable assets within the jurisdiction. This is an area where the interface between Russian procedural requirements and the foreign client's practical capacity to provide a meaningful undertaking will require early coordination between instructing counsel and Russian lawyers. The Asset Tracing & Recovery practice at Vetrov & Partners regularly advises foreign law firms on the design and execution of interim relief applications in Russian courts, including the post-order management of challenges. The firm has also published a detailed analysis of shifting court practice on interim relief at Court practice shift on interim relief applications in Russian courts and a risk-oriented companion piece at Key risk points in interim relief applications before Russian courts.

• Court practice shift on interim relief applications in Russian courts
• Key risk points in interim relief applications before Russian courts
• Asset Tracing & Recovery — practice overview

Q: What does this ruling change for foreign law firms instructing Russian lawyers on interim relief matters?

A: The ruling makes explicit a standard that has been developing in Russian appellate practice but was not consistently applied at first instance: that an interim relief order requires positive, forward-looking evidence of a real and near-term risk of asset dissipation. Historical evidence of asset movements, or evidence of a corporate structure that is capable of dissipating assets, will not automatically sustain an order on appeal. For foreign law firms instructing Russian lawyers, this means the evidentiary package must be designed for the appellate standard from the outset, rather than calibrated to the more permissive first-instance threshold. It also means that enforcement strategies built around an existing first-instance order should be reviewed for appellate vulnerability.

Q: What should foreign companies and their advisers do in light of this decision?

A: Three steps are advisable. First, any existing Russian interim relief order in a matter involving offshore assets should be assessed against the evidentiary standard articulated by the appellate court — specifically, whether the dissipation risk analysis rests on prospective evidence or primarily on historical or structural inference. Second, applications not yet filed should be redesigned, with the evidentiary framework and the undertaking as to damages both prepared to the appellate standard. Third, instructing counsel should confirm with their Russian lawyers that the application package addresses the undertaking-as-to-damages requirements that Russian courts may scrutinise. Vetrov & Partners advises on all three stages and can review existing application packages on request.

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 and their instructing counsel on interim relief applications, asset freezing, and enforcement proceedings before Russian arbitrazh courts and the Russian IP Court. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with direct partner involvement on every engagement. The firm works directly with foreign law firms as local counsel in contentious Russian matters.

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/

In advising foreign creditors and their instructing firms on asset recovery in Russia, one issue recurs with striking consistency: foreign counsel arrives at the enforcement stage with a clear picture of a judgment debtor's liabilities but without the asset information needed to make enforcement viable. Third-party disclosure orders — applications compelling banks, registrars, and other institutional holders to produce information about a judgment debtor's assets — have been a contested procedural tool in Russian proceedings for some years. A recent ruling by the Russian Supreme Court has clarified the conditions under which such orders will be sustained, and the reasoning carries material implications for creditors conducting cross-border asset tracing and for the foreign law firms instructing Russian counsel on their behalf.

Asset tracing in Russian civil proceedings has never followed a single, settled procedural path. Unlike the position in many common-law jurisdictions, there is no direct Russian equivalent to a Norwich Pharmacal order or a Bankers Trust application as a standalone pre-trial mechanism. Creditors seeking to identify concealed or transferred assets have historically relied on a combination of court-ordered disclosure within enforcement proceedings, requests through bailiff services, and — in more complex matters — parallel insolvency tools that carry broader investigative reach.

Third-party disclosure in Russian proceedings typically arises in one of two procedural contexts: as a court order directed at a third party within ongoing enforcement proceedings before an arbitrazh court or court of general jurisdiction, or as a request made through the bailiff service with judicial authorisation. The boundaries between these routes, and the standard of justification required for each, had been applied inconsistently across circuits. In some jurisdictions, courts had taken an expansive view, granting disclosure requests on a relatively low threshold of relevance; in others, courts had imposed stricter proportionality requirements, requiring creditors to demonstrate both that the information sought was unavailable through other means and that the third party held information specifically referable to identifiable assets. That inconsistency — well known to practitioners working across the Siberian, Ural, and Volga-Vyatka circuits — had created planning difficulties for foreign creditors and their instructing counsel, who faced materially different prospects depending on where the debtor's assets were registered.

The matter that reached the Russian Supreme Court arose in the context of enforcement proceedings following a substantial commercial judgment. The respondent debtor had taken steps to restructure its asset holdings in the period following judgment, and the creditor sought disclosure from a third-party financial institution regarding the debtor's accounts and transaction history across a defined period. The lower and appellate courts had divided on whether the application met the required justificatory threshold, and the matter was referred upward on the question of applicable standard.

The Supreme Court's ruling addressed the applicable standard for third-party disclosure orders in enforcement-stage proceedings with a degree of analytical clarity that the prior case law had lacked. The court confirmed that such orders are available as a procedural mechanism within enforcement proceedings, but articulated a three-part framework governing their grant.

First, the court held that an applicant must demonstrate relevance — specifically, that the information sought from the third party is referable to assets or transactions that are the subject of the enforcement proceedings, and not a general investigation into the debtor's affairs. A disclosure order cannot be used as a fishing expedition; the request must identify, with reasonable particularity, the category of assets or transactions about which disclosure is sought.

Second, the court addressed necessity: the creditor must establish that the information cannot reasonably be obtained through enforcement mechanisms already available, including those exercisable by the bailiff service. Where standard enforcement tools — levy on identified accounts, registration of enforcement notices against known property — are adequate, the more intrusive mechanism of third-party disclosure against a financial institution or registrar requires additional justification.

Third, and perhaps most significantly for practitioners, the court affirmed that proportionality considerations apply to the scope of the order. Even where the first two elements are met, the court retains discretion to limit the temporal or subject-matter scope of the disclosure required, so as not to impose a disproportionate burden on the third party. This proportionality element, previously present in some circuit court decisions but not consistently applied, now has Supreme Court authority behind it.

"This ruling brings Russian enforcement procedure materially closer to the standard applied in comparative European jurisdictions, which matters for foreign firms instructing Russian counsel: the framework is now principled and predictable, even if the threshold is higher." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign law firms assessing the implications of this ruling for asset recovery mandates already under instruction — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms instructing Russian counsel on cross-border asset tracing and recovery matters, this ruling has several practical consequences worth incorporating into engagement planning.

The articulation of a three-part relevance-necessity-proportionality framework means that disclosure applications must now be prepared with greater specificity than some creditors have previously brought to Russian enforcement proceedings. A request that identifies a class of financial institutions without connecting that request to particular transactions or asset categories within the enforcement proceedings is more likely to be refused or substantially narrowed. Instructing firms should ensure that any disclosure strategy is developed alongside the substantive enforcement plan, not as an afterthought once standard enforcement routes have been exhausted.

The necessity element has a direct bearing on sequencing. Creditors who proceed immediately to third-party disclosure applications without first attempting standard enforcement channels — or without demonstrating why those channels are inadequate for the specific matter — may find applications rejected on this ground. In practice, this reinforces the importance of a documented enforcement strategy: Russian counsel will need to show not only what assets the creditor seeks to trace, but why the available bailiff-service mechanisms cannot adequately identify or recover those assets.

For matters involving debtors who have restructured assets post-judgment, the ruling's clarification on temporal scope is useful. The court's confirmation that a disclosure order may appropriately cover a defined historical period — where the applicant can demonstrate that asset transfers in that period are relevant to the enforcement proceedings — gives creditors a principled basis for requesting transaction history covering the restructuring window. That basis did not exist as clearly before this ruling.

For foreign firms coordinating multi-jurisdictional recovery with Russian enforcement proceedings as one component, the ruling's framework will be familiar in structure, even if the procedural implementation differs from common-law disclosure regimes. Firms who have worked with third-party disclosure orders in Russian proceedings as a tool will find that the new framework rewards the kind of asset-specific, evidence-grounded approach that characterises well-prepared cross-border enforcement. A practical guide to third-party disclosure orders in Russian proceedings is available in the Insights archive for firms approaching this procedural area for the first time.

The firm's Asset Tracing & Recovery practice has advised creditor-side clients in enforcement matters where disclosure applications have been central to the recovery strategy, including matters before arbitrazh courts in Novosibirsk, Yekaterinburg, and across the Siberian Federal District. The Matters section of this site sets out representative examples. For matters where the debtor's assets span multiple jurisdictions, the firm collaborates with instructing counsel on disclosure strategy across the full recovery structure.

Firms instructing Russian counsel on enforcement matters where third-party disclosure is in scope — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What does this ruling change for creditors using third-party disclosure orders in Russian enforcement proceedings?

A: Before this ruling, the standard for granting third-party disclosure orders varied significantly across Russian court circuits, with some courts applying a low relevance threshold and others requiring detailed justification. The Supreme Court has now established a uniform three-part framework — relevance, necessity, and proportionality — that applies across all courts. Creditors can no longer rely on expansive disclosure orders based on general relevance alone. Applications must specify the category of assets or transactions sought, demonstrate that standard enforcement channels are inadequate, and accept that the court may limit the scope of disclosure even where the substantive threshold is met. The ruling brings greater predictability for creditors and their instructing firms, but it requires more careful preparation of disclosure applications at the outset.

Q: What should foreign law firms do in light of this decision when instructing Russian counsel on asset tracing matters?

A: Foreign firms instructing Russian counsel should revisit their disclosure strategy for any enforcement matter where third-party disclosure is anticipated. Specifically: the connection between the information sought and the assets subject to enforcement proceedings should be documented from the outset, rather than developed reactively once standard enforcement tools have been tried. Firms should also ensure that the enforcement plan is sequenced to show that the bailiff-service mechanisms have been considered and found inadequate for the specific matter, before a court-ordered third-party disclosure application is made. Where the debtor has restructured assets post-judgment, the temporal window of the disclosure request should be calibrated to that restructuring period and supported with available transaction evidence. Early-stage coordination between instructing counsel and Russian local counsel — before enforcement proceedings commence — materially improves the prospects of a well-framed disclosure application.

• Third-party disclosure orders in Russian proceedings: a legal overview
• A practical guide to third-party disclosure orders for foreign creditors
• Asset Tracing & Recovery: practice overview

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

The firm's Asset Tracing & Recovery practice advises foreign creditors, distressed investors, and the foreign law firms instructing on their behalf in enforcement proceedings before Russian arbitrazh courts and courts of general jurisdiction. With over 1,000 matters handled since inception, the team combines procedural depth in disclosure and enforcement mechanisms with 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/

In the course of advising foreign law firms on asset tracing and enforcement matters in Russia, one procedural instrument generates more uncertainty than almost any other: the international letter rogatory. Requests for judicial assistance directed at Russian courts and state authorities have always operated within a layered treaty framework — the 1993 CIS Convention on Legal Assistance, bilateral treaties, and in limited respects the Hague Evidence Convention — but the domestic procedural rules governing how Russian courts receive and act on those requests have remained opaque to foreign practitioners. A decision handed down by a Russian commercial court in early 2026 has begun to change that, clarifying how rogatory requests directed at Russian authorities should be framed, routed, and processed, and — critically — what happens when they are not.

International letters rogatory are formal requests from a foreign court or authority to a Russian counterpart, asking it to perform a specific judicial act: serving process, taking witness evidence, or in commercial and enforcement contexts, compelling disclosure of asset information held by Russian state registries. The legal basis for such requests in Russia derives primarily from treaty obligations — the Minsk Convention for CIS member states, bilateral legal assistance treaties with several European and Asian jurisdictions, and domestic procedural rules that implement those treaty obligations in civil and commercial proceedings.

The matter at issue arose in the context of a cross-border asset recovery effort. A foreign creditor, acting through counsel in its home jurisdiction, sought to obtain information held by a Russian state registry — information directly relevant to identifying and locating assets of a judgment debtor with registered interests in Russia. The foreign court issued a letter rogatory, directed through the central authority channel, requesting that the relevant Russian authority produce specified documentary information.

Two procedural questions presented themselves before the Russian court. First, whether the rogatory request satisfied the formal requirements imposed by Russian domestic procedure for incoming requests — requirements that, in practice, go beyond the treaty text and include specific translation, notarisation, and routing formalities. Second, and more significantly, whether the Russian court retained any substantive discretion to decline execution of a formally compliant request on grounds that the information sought was commercially sensitive or subject to domestic confidentiality protections.

The court's ruling addressed both questions in terms that will be of direct interest to foreign counsel managing cross-border enforcement files.

On the formal requirements question, the court confirmed that Russian procedural rules impose a strict compliance standard: a letter rogatory that does not satisfy each formal requirement — certified translation into Russian, notarised authentication of the issuing court's authority, and routing through the designated central authority rather than direct to the executing court — will not be executed, regardless of the treaty obligation to cooperate. The court declined to apply a curative discretion to overlook formal defects. This position, while broadly consistent with prior administrative practice, is now confirmed at the level of a reasoned judicial decision.

On the more significant question of substantive refusal grounds, the court's reasoning was notably restrictive. It held that a formally compliant rogatory request, directed at a Russian state authority holding information of the type specified in the applicable treaty, could not be refused on grounds of commercial sensitivity or domestic confidentiality rules alone, provided the requesting foreign court had articulated a clear nexus between the information sought and the underlying proceedings. The court distinguished between information held by private parties — where domestic confidentiality protections retain force — and information held by state registries in their public capacity, which it characterised as subject to a narrower refusal regime under the applicable treaty framework.

"This ruling draws a line that foreign counsel have long needed: registry-held asset data is not shielded by commercial confidentiality when a foreign court's rogatory request is formally compliant and treaty-grounded." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The practical effect is meaningful. Creditors seeking disclosure of registered asset data — ownership of real property, vehicle registrations, participatory interests in Russian legal entities — through a properly constituted rogatory request now have a clearer basis for challenging a refusal by the executing Russian authority. The decision does not guarantee execution, and appeals to the applicable treaty text remain necessary, but it removes one category of previously common objection from the executing authority's repertoire.

If you are advising a client with enforcement interests in Russia and need confirmed Russian counsel to prepare or support a letters rogatory request — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms managing cross-border enforcement and asset tracing files, the ruling has three practical consequences worth noting.

First, formal compliance is non-negotiable and must be verified by Russian counsel before the request leaves the foreign jurisdiction. The court's confirmation that formal defects are fatal — not curable — means that a request drafted without input from a Russian-qualified lawyer familiar with current central authority practice will frequently fail at the threshold, wasting procedural time and alerting the debtor. Firms instructing Russian lawyers should ensure that this review occurs at the drafting stage, not after transmission.

Second, the distinction the court draws between state registry data and privately held information has direct implications for how asset tracing strategies in Russia are sequenced. Rogatory requests are a more viable instrument for obtaining registry-held information than they are for obtaining documents held by private counterparties, banks, or advisers. Foreign counsel should calibrate their expectations accordingly and explore parallel routes — including applications under Asset Tracing & Recovery practice mechanisms — where private-party disclosure is needed.

Third, the ruling is likely to be cited in subsequent proceedings, including before the courts of CIS member states whose legal assistance frameworks closely track Russian procedural norms. Practitioners advising on matters that touch Russia, Kazakhstan, Belarus, or other CIS jurisdictions should note that this reasoning may travel — and should factor it into their treaty analysis. The companion analysis in International Letters Rogatory Directed at Russian Authorities: A Practitioner Overview addresses the broader procedural landscape in detail.

For firms without an established Russian counsel relationship, the window between a foreign judgment or arbitral award and the commencement of enforcement is typically the most consequential period. Rogatory requests directed at Russian registries are one of the tools available during that window — but only if they are prepared correctly from the outset. The guidance published alongside Rospatent's recent clarification on international letters rogatory, available at Rospatent Issues Guidance on International Letters Rogatory, provides further context for IP-adjacent asset tracing situations.

For enforcement matters touching Russian assets more broadly, the cross-border disputes practice and the firm's Matters Hub record provides additional context on the procedural tools available at each stage of the recovery sequence.

To discuss a cross-border enforcement or asset tracing matter involving Russian authorities — speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What does this ruling change for foreign counsel seeking information from Russian state registries?

A: The ruling confirms that Russian courts will not execute a rogatory request that fails to satisfy domestic formal requirements — certified translation, notarised authentication, and correct central authority routing — regardless of the underlying treaty obligation. It also restricts the grounds on which a Russian executing authority may refuse a formally compliant request directed at state registry data, removing commercial confidentiality as a standalone refusal basis where the foreign court has established a clear nexus between the requested information and the underlying proceedings. In practice, this makes properly prepared rogatory requests a more viable instrument for identifying Russian-registered assets than they were under prior administrative practice.

Q: What should foreign law firms do in light of this decision?

A: Firms should ensure that any letters rogatory directed at Russian authorities are reviewed and, where appropriate, drafted with input from Russian-qualified counsel before transmission. The formal requirements are strict and fatal if not met. Beyond formal compliance, firms should also review whether the information they are seeking is registry-held — in which case this ruling supports execution — or privately held, in which case a different procedural strategy may be needed. Firms without an established Russian counsel relationship should treat this as the moment to put one in place, particularly where enforcement proceedings are live or anticipated.

• International Letters Rogatory Directed at Russian Authorities: A Practitioner Overview
• Rospatent Issues Guidance on International Letters Rogatory
• Asset Tracing & Recovery Practice

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 and recovery practice advises foreign creditors, foreign law firms, and institutional investors on the full sequence of enforcement steps available in Russia: from pre-judgment asset searches and interim measures through to execution against identified assets. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

In a decision handed down in the first quarter of 2026, a Russian commercial court addressed a question that has become increasingly significant for foreign law firms advising clients with Russian assets: whether and to what extent Russian currency control legislation governs the repatriation of funds derived from cross-border transactions when the resident counterparty has already transferred assets offshore. The ruling drew on the repatriation obligation framework that sits at the centre of Russian currency control law — an area where the regulatory position has evolved materially over the past several years — and produced a clarification that is directly relevant to foreign counsel structuring recovery strategies for clients holding claims against Russian entities.

Russian currency control legislation imposes a repatriation obligation on resident legal entities: funds due under foreign trade contracts must be returned to Russia within the timeframe specified in the contract or, absent a contractual term, within the period prescribed by the applicable regulatory instructions. The obligation is administered jointly by the Federal Tax Service and, for transactions crossing the customs frontier, the Federal Customs Service. Penalties for non-repatriation are assessed administratively and are graduated by the amount unrepatriated and the duration of the delay; in practice, they are among the more actively enforced provisions of Russian currency control law.

The dispute at issue arose from a foreign trade contract under which a Russian resident company was obligated to repatriate export proceeds. The resident company had, in the period preceding the regulatory audit, transferred a significant portion of its liquid assets to a related offshore entity — a structure that, prior to the ruling, some advisers had argued placed those assets outside the reach of the repatriation obligation. The Federal Tax Service, having identified the transfers during a currency control audit, assessed a penalty and sought judicial confirmation of the enforcement position. The resident company challenged the assessment, arguing that the transferred assets had ceased to be "funds due under the foreign trade contract" once the intercompany transfer was completed.

The court thus faced a question of regulatory characterisation: does the repatriation obligation attach to the original receivable, or does it follow the form in which that receivable is ultimately held?

The court rejected the resident company's characterisation and upheld the administrative penalty. In its reasoning, the court held that the repatriation obligation attaches to the economic substance of the contractual receivable, not merely to the form in which funds are held at the time of the audit. Intercompany transfers to related offshore entities do not, in the court's analysis, extinguish the underlying repatriation obligation: the resident remains liable for non-repatriation to the extent that funds are traceable — however transformed in form — to the original foreign trade proceeds.

Critically, the court also addressed the evidentiary standard. The Federal Tax Service was required to demonstrate a traceable nexus between the offshore transfer and the foreign trade receivable; a bare allegation of asset movement was insufficient. In this case, the nexus was established through banking records and internal transfer documentation that the resident company was required to produce under the currency control audit procedure.

The ruling also engaged, briefly but materially, with the EAEU dimension. The court noted that EAEU membership does not modify the repatriation obligation for transactions with non-EAEU counterparties; the carve-outs applicable to intra-EAEU settlements applied only where both the originating and receiving entities were EAEU-resident. This clarification is significant because some advisers had argued that EAEU membership created a broader safe harbour for intercompany structuring within CIS-adjacent structures.

"This ruling closes a planning gap that practitioners had identified in offshore structuring for Russian residents: the repatriation obligation now follows economic substance, not formal ownership — and that has direct consequences for recovery strategy."

— Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

If you are advising a client with exposure to Russian currency control enforcement, or if the recovery strategy for a Russian-asset matter requires an assessment of this ruling's implications — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign counsel instructing Russian lawyers on asset recovery or repatriation matters, this decision has several immediate practical implications.

First, the substance-over-form approach adopted by the court significantly narrows the utility of offshore intercompany transfers as a mechanism for shielding assets from currency control enforcement. Foreign firms advising clients who hold contractual claims against Russian residents should now assume that pre-enforcement asset movements may not be treated as dispositive by Russian courts — a point that has direct relevance to pre-litigation asset mapping.

Second, the evidentiary nexus requirement cuts both ways. For creditors, it confirms that the Federal Tax Service and enforcement courts will require traceable documentation — which creates disclosure obligations during the audit process but also, from a creditor's perspective, means that the evidentiary trail the regulator must establish is one that experienced local counsel can interrogate. For a foreign law firm instructing local counsel in Russia on enforcement, understanding what the regulator is required to prove is as important as understanding the liability rule itself.

Third, the EAEU clarification matters for matters involving CIS-adjacent holding structures. It is not uncommon for Russian residents operating within cross-border corporate groups to hold assets through entities in Kazakhstan, Belarus, or Armenia — all EAEU members. The court's reading of the EAEU carve-out as limited to intra-EAEU settlements, rather than to intra-EAEU corporate ownership, forecloses a structuring argument that had been advanced in several prior matters. Foreign counsel should review the corporate and ownership structure of any Russian counterparty with EAEU-based affiliates before drawing conclusions about repatriation exposure.

The firm has acted in several matters where the repatriation obligation intersected with cross-border recovery strategy. In a recent engagement, counsel acted for a European trade creditor seeking to enforce a contractual claim against a Russian resident that had, prior to proceedings, transferred its primary liquid assets to a related Cypriot entity. The repatriation framework analysis — and its interaction with the enforcement procedure — was central to establishing the recovery route. The outcome of that engagement is consistent with the court's approach in the decision discussed here.

For firms instructing Russian counsel in matters of this nature, the question of which claims are available, in which forum, and on what evidentiary basis is one that requires close coordination from the outset. The Supreme Court clarification on asset tracing and recovery addressed related procedural points that are directly relevant to the enforcement pathway following a currency control ruling of this kind.

For a peer-to-peer consultation on instructing Russian lawyers in asset repatriation or currency control enforcement matters — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Supreme Court clarification on asset tracing and recovery
• Navigating asset repatriation and Russian currency control: a practical guide
• Asset tracing and recovery in Russia

Q: What does this ruling change about how Russian currency control obligations are assessed?

A: Prior to this decision, there was an arguable gap in the enforcement position: some advisers took the view that intercompany transfers to offshore entities, once completed, removed funds from the scope of the repatriation obligation because the resident no longer held the relevant receivable in its own name. The court rejected that analysis. The repatriation obligation now attaches to the economic substance of the original foreign trade receivable rather than to the formal ownership of the funds at the time of a currency control audit. The practical consequence is that pre-audit intercompany transfers to related offshore entities will not, by themselves, extinguish the resident's repatriation liability where a traceable nexus to the original export proceeds can be established.

Q: What should foreign companies and their advisers do in light of this decision?

A: Three steps are advisable. First, review any ongoing or anticipated enforcement or recovery strategy that assumed offshore intercompany transfers would be treated as dispositive — that assumption no longer holds under this ruling, and the analysis should be updated before proceedings are commenced. Second, assess the corporate structure of any Russian counterparty with EAEU-affiliated entities: the ruling's narrow reading of the EAEU carve-out means that CIS-adjacent holding arrangements do not provide the protection some had expected. Third, engage experienced Russian counsel at an early stage. The evidentiary nexus requirement that the court imposed on the Federal Tax Service is the principal point at which creditor-side strategy and regulatory enforcement interact — and navigating that intersection requires local procedural knowledge. For firms already instructing Russian lawyers, it is worth confirming that the instruction covers the repatriation dimension of the matter expressly.

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 and recovery practice advises foreign creditors, trade counterparties, and institutional investors on cross-border recovery strategy involving Russian assets, including currency control exposure, offshore asset tracing, and enforcement before Russian commercial courts. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

In advising foreign law firms on the enforcement of English court orders against Russian-domiciled debtors, one question arises more consistently than any other: does Russian court practice on this question have any settled content, or is each case decided afresh? A recent clarification issued by a Russian arbitrazh court — addressing precisely when and on what basis an English court order may be recognised and enforced in Russia — provides a useful, if sobering, answer for instructing counsel.

The structural obstacle is longstanding. Russia and the United Kingdom are not parties to any bilateral treaty providing for the mutual recognition and enforcement of civil judgments. In the absence of such a treaty, Russian arbitrazh courts have had to construct a doctrinal basis for recognition from their own procedural code, which permits recognition of foreign court decisions either on the basis of an international treaty or — where no treaty exists — on the principle of reciprocity.

Reciprocity, in this context, means that a Russian court will consider whether the courts of the foreign state in question would reciprocally enforce a Russian judgment in comparable circumstances. The difficulty with English court orders specifically is that this analysis has not produced a consistent answer across Russian judicial circuits. Some courts have found that sufficient reciprocity exists; others have concluded that, given the practical rarity of Russian judgments being enforced in England, the reciprocity condition is not met.

The matter before the court concerned a foreign creditor — instructed by a firm outside Russia — seeking to recover against a Russian commercial counterparty on the basis of a money judgment issued by an English court. The creditor had been unable to identify sufficient Russian-domiciled assets against which to enforce domestically in England and had turned to Russian proceedings as the primary recovery route. The court's analysis of whether the English judgment should be recognised, and on what conditions, is the subject of this comment.

The court declined to recognise the English court order on the primary grounds that neither a treaty basis nor a demonstrable basis of reciprocity had been established. In reaching that conclusion, the court applied a two-stage analysis. First, it examined whether any relevant international treaty — including the CIS conventions on legal assistance — applied. It found that they did not: those instruments cover CIS member-state judgments, and English judgments fall outside their scope. Second, it turned to the reciprocity question and concluded that the creditor had not discharged the burden of demonstrating that English courts would, in practice, recognise an equivalent Russian commercial judgment.

The court also addressed the public policy reservation. Even if reciprocity had been established, it noted, enforcement of a judgment obtained in proceedings where the defendant had had no proper opportunity to present its case before the English court would likely engage the public policy exception — a ground for refusal that Russian arbitrazh courts apply with some frequency in proceedings involving foreign judgments and foreign parties.

A notable element of the reasoning concerned the burden of proof on reciprocity. The court held that this burden rests with the party seeking recognition, not with the respondent. This is consistent with the prevailing approach in the Siberian and Ural circuits, though practice elsewhere has at times placed a lighter evidential requirement on the claimant.

"The ruling is a useful restatement of a structural problem: English court orders against Russian debtors require a theory of enforcement that does not depend on reciprocity alone, and foreign counsel need to build that theory from the outset." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

A second ground of refusal addressed jurisdiction: the court found that even if recognition had been available in principle, the English court's assertion of jurisdiction over the Russian defendant did not satisfy the conditions that Russian arbitrazh procedure requires before a foreign court's jurisdiction is treated as proper. This is an aspect of the case that deserves particular attention — it suggests that jurisdiction challenges may be available as an independent line of defence in proceedings to resist recognition, even where the substantive merits of the foreign judgment are not in dispute.

If you are instructing Russian lawyers on behalf of a client with an English court order against a Russian-domiciled defendant — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms advising creditors who hold English court orders and are considering Russian enforcement proceedings, this decision reinforces several practical points that should inform how instructions are structured from the outset.

The first and most significant point concerns the selection of enforcement route. Where a creditor has an arbitral award — from LCIA, ICC, or another institutional seat — rather than a court judgment, the enforcement route through the New York Convention framework is materially stronger in Russia than the treaty-less position applicable to English court judgments. Where the client's order is a court judgment and not an arbitral award, the strategy requires a different approach: rather than seeking direct recognition of the foreign judgment, counsel should consider whether the underlying debt can be re-litigated before a Russian arbitrazh court on its merits. This is a longer and more resource-intensive route, but it is frequently the only reliable one.

The second point concerns asset position. The legislative and procedural landscape for tracing assets in Russia has developed considerably, and foreign creditors who engage Russian counsel before commencing recognition proceedings — rather than after — are better placed to identify and protect assets before a debtor has notice of enforcement intent. The decision under review is a reminder that recognition proceedings themselves may be protracted; a creditor whose debtor has dissipated Russian assets during the recognition phase may find that a successful recognition argument is ultimately without practical value.

The third point is for instructing firms specifically: the reciprocity burden rests with the applicant, and satisfying it requires evidence about English court practice on Russian judgments. This is not a matter of Russian law alone — it requires co-ordinated input from English solicitors who can speak to what English courts have in practice done with Russian commercial judgments. Firms considering instructing Russian counsel on this type of matter should plan for that evidentiary co-ordination from the outset. The practice briefing on enforcing English court orders in Russia sets out the standard documentation framework we work within.

For foreign creditors who are simultaneously exploring asset identification, the firm's asset tracing and recovery practice can support the Russian-side enquiry in parallel with recognition proceedings, including through the Russian court's interim relief procedures.

To discuss instructing us as Russian counsel on enforcement strategy — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Legislative amendment affecting enforcing English court orders in Russia
• Enforcing English court orders in Russia: practitioner briefing
• Asset tracing and recovery in Russia: an overview for foreign creditors

Q: What does this ruling change?

A: The ruling does not introduce a new legal rule — the absence of a UK–Russia bilateral enforcement treaty has been the structural position for some time. What it clarifies is the burden and method of the reciprocity analysis that Russian arbitrazh courts apply in lieu of a treaty basis. Specifically, the decision confirms that the burden of demonstrating reciprocity rests with the applicant seeking recognition, not with the party resisting it. It also articulates the jurisdiction-challenge ground as an independent basis on which recognition may be refused, distinct from the reciprocity and public policy grounds. For instructing firms, the practical change is that the evidential preparation required before commencing recognition proceedings has become more defined — and more demanding.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors holding English court orders against Russian-domiciled debtors should treat direct recognition proceedings as one option in a broader enforcement strategy, not as the primary route. The immediate steps are: first, establish the Russian asset position before the debtor has notice of intended enforcement; second, assess whether an arbitral route is available — either because the underlying contract contained an arbitration clause or because a parallel arbitral claim can be structured; and third, engage Russian counsel and English solicitors jointly to build the reciprocity evidence before proceedings are filed. Where re-litigation on the merits before a Russian arbitrazh court is the chosen route, that process should begin as soon as the asset position is confirmed.

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

The firm's asset tracing and recovery practice advises foreign creditors, foreign law firms, and institutional investors on the identification and enforcement of claims against Russian-domiciled debtors. This includes support for recognition proceedings, interim relief applications before Russian arbitrazh courts, and parallel asset-tracing work across the Siberian and Ural federal districts. With over 1,000 matters handled since inception, the team offers direct partner involvement on every engagement — no delegation to junior fee-earners.

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/

In the past several years of advising on cross-border asset recovery and instructing experts in Russian arbitrazh proceedings, a pattern has emerged that deserves the careful attention of foreign disputes counsel: Russian cassation courts are applying a noticeably more exacting standard to forensic accounting evidence tendered in asset investigation matters. A recent cassation ruling — one that overturned both the first-instance and appellate courts in a commercial dispute involving concealed asset transfers — crystallises this shift and has direct practical implications for foreign firms instructing Russian counsel on forensic accounting asset Russia investigations.

Asset tracing in Russian court proceedings has long relied on court-appointed or party-commissioned forensic accounting experts to reconstruct transaction chains, establish the economic substance of related-party dealings, and quantify alleged dissipation. Under the procedural framework governing commercial courts, expert evidence of this nature carries significant evidential weight, particularly where documentary disclosure has been incomplete. The practice area of Asset Tracing & Recovery at Vetrov & Partners has engaged court-appointed forensic accountants across a range of creditor-side mandates in the Siberian and Ural federal districts, and the treatment of expert conclusions at cassation level has been a recurring variable in predicting enforceability of first-instance outcomes.

The matter under analysis arose from a creditor's application to recover assets that had allegedly been transferred from a principal debtor entity to a network of affiliated companies in the period preceding formal insolvency proceedings. The claimant relied substantially on a forensic accounting expert's conclusions as to the economic coherence of the transfer scheme and the absence of legitimate commercial rationale. The lower courts admitted the expert evidence and found in favour of the claimant on the core asset recovery claim.

On cassation review, however, the panel identified what it characterised as a fundamental methodological deficiency in the expert's conclusions. The court found that the expert had drawn inferences about transactional intent from accounting materials that, on the panel's analysis, supported only factual reconstruction of the transfer sequence — not a conclusion as to economic substance or purpose. This distinction — between what the numbers show and what the numbers mean — proved decisive.

For foreign firms seeking experienced local counsel Russia on asset recovery and forensic accounting disputes — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The cassation court's reasoning proceeded in three stages, each of which has broader implications for how forensic accounting evidence is structured and deployed in Russian asset investigations.

First, the panel scrutinised the expert's mandate as defined by the originating court order. It found that the questions put to the expert had been framed too broadly, permitting conclusions that strayed from accounting analysis into legal characterisation. Russian procedural rules, as the cassation court reaffirmed, draw a clear line between the expert's role — confined to technical and methodological analysis — and the court's function as the exclusive arbiter of legal consequence. Where an expert's report conflates these roles, the conclusions are at risk of being set aside, irrespective of their underlying analytical quality.

Second, the court examined the methodological underpinning of the expert's conclusions. The panel found that the expert had relied on a valuation methodology that, while defensible in a general accounting context, had not been validated against the specific characteristics of the transactions under review. The court held that a failure to address material structural differences between the subject transactions and the comparables used in the expert's analysis undermined the reliability of the conclusions at a foundational level. This is consistent with the approach documented in related commentary on how Russian courts approach forensic accounting evidence in asset proceedings.

Third, the panel addressed the appellate court's failure to engage with the respondent's methodological objections. The cassation court found that the appellate court had, in substance, deferred to the expert's conclusions without independently assessing the respondent's expert-counter position — a procedural error that independently warranted remittal.

"[The ruling confirms what practitioners in this field have observed for some time: cassation panels are willing to look behind expert conclusions and assess methodology directly — a standard that demands careful expert selection and mandate drafting from the outset.]" — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign law firms instructing Russian lawyers in asset investigation matters, this ruling shifts the weight of the engagement towards expert selection and mandate design — areas that are frequently treated as secondary to the broader litigation strategy. The cassation court's scrutiny of the expert's mandate framing is particularly significant: the questions put to a forensic accounting expert in Russian proceedings must be drafted with precision, confining the expert to technical analysis and explicitly excluding legal characterisation. This is a task that benefits from early involvement of local counsel familiar with how cassation-level courts in the relevant circuit have historically framed admissibility questions.

The methodological validation point has a practical consequence for cases where the asset transfer patterns are structurally unusual — transactions between thinly capitalised entities, intra-group loans at non-market rates, or multi-jurisdictional routing. In these matters, an expert who applies a standard valuation or accounting methodology without addressing the specific structural features of the subject transactions is exposed to a cassation-level challenge of the kind that undid the claimant in this matter. Instructing foreign firms should, at the outset, discuss with local counsel the basis on which comparables will be selected and validated.

The appellate deference point carries a different practical implication. It signals that Russian cassation courts expect lower courts to engage substantively with competing expert positions — not simply to adopt the court-appointed expert's conclusions by default. For creditor-side litigants, this is arguably favourable: it means that a well-constructed counter-expert position, even one that does not wholly displace the primary expert, may create a cassation ground if the appellate court fails to address it adequately. Respondents facing asset freeze applications should similarly ensure that their expert challenges are articulated with sufficient precision to generate a reviewable record. The firm's experience in creditor-side mandates across the Matters portfolio reflects the value of structuring the expert record with cassation review in mind from the earliest stage of proceedings.

This ruling also matters in the context of cross-jurisdictional enforcement. For Russia ruling foreign parties — whether as creditors seeking to enforce a judgment abroad or as respondents resisting enforcement — the integrity of the forensic accounting record assembled in Russian proceedings will be scrutinised by foreign enforcement courts. A Russian court decision grounded in expert evidence that was challenged but not adequately addressed at appellate level presents an arguable vulnerability at the enforcement stage. Foreign counsel instructing on Russian asset recovery should treat the quality of the expert record as a cross-border risk variable, not merely a domestic procedural matter. See also the related analysis of Supreme Court enforcement trends in forensic accounting matters for the broader direction of travel.

If you are advising clients on Russian asset investigations and require experienced local counsel — discuss your matter in confidence: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Supreme Court enforcement trends in forensic accounting matters
• How Russian courts approach forensic accounting evidence in asset proceedings
• Asset Tracing & Recovery — Practice Overview

Q: What does this ruling change?

A: The ruling clarifies that cassation panels in Russian commercial court proceedings will assess not only whether a forensic accounting expert's conclusions are supported by the materials, but whether the methodology applied is valid for the specific transaction type under review and whether the expert's mandate was properly confined to technical analysis. Lower courts can no longer treat acceptance of a court-appointed expert's conclusions as effectively insulated from cassation scrutiny. For creditors relying on forensic accounting evidence in asset investigation proceedings, this means that the quality and precision of the expert instruction, and the methodological rigour of the report, are now directly relevant to the durability of a first-instance or appellate finding on cassation review.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors and their instructing counsel should revisit the approach to expert engagement in Russian asset proceedings at three points. At the outset, the expert's mandate must be drafted with care to confine conclusions to accounting and financial analysis, avoiding characterisations of legal intent or purpose that properly belong to the court. During proceedings, the methodological basis of the expert's analysis should be validated for the specific characteristics of the subject transactions, particularly where those transactions differ structurally from standard market arrangements. And at the appellate stage, any counter-expert position advanced by the respondent should be addressed specifically and on the merits, rather than left for the court to dismiss by implication, in order to preserve the integrity of the evidential record against cassation challenge.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 – Russia's principal legal directory – for eight consecutive years, and 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 seeking local counsel in Russian asset investigation and enforcement proceedings. The team has acted in creditor-side mandates across the Siberian and Ural federal districts, with direct partner involvement at every stage. With over 1,000 matters handled since inception, the practice brings procedural depth and a forensic understanding of how Russian cassation courts assess expert evidence.

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/

In the past two years of advising on Russian asset recovery mandates alongside foreign counsel, one structural tension recurs with increasing frequency: the difficulty of sequencing Russian enforcement steps against a backdrop of live European proceedings targeting the same assets or the same obligor. Recent judicial practice suggests that Russian courts are beginning to articulate clearer — if still evolving — positions on how they treat the existence of parallel foreign proceedings, what weight they assign to foreign interim measures, and under what conditions they will coordinate rather than compete with enforcement steps taken abroad. For foreign law firms instructing local counsel Russia on cross-border asset recovery matters, understanding those emerging positions is now a practical necessity rather than an academic interest.

The matters that have contributed most visibly to this emerging body of Russian judicial practice share a common fact pattern: a claimant — typically a foreign trade creditor or institutional investor — holds a judgment or award obtained in a European jurisdiction and seeks to trace and recover assets held by the respondent within Russia, while simultaneously maintaining parallel enforcement or freezing proceedings in one or more European courts.

The Russian-side proceedings in these matters have generally involved one of two procedural routes: either a direct application to an arbitrazh court for recognition and enforcement of a foreign judgment or arbitral award under the standard cross-border asset recovery framework, or an independent claim on the underlying obligation before Russian courts, pursued where the foreign award is not straightforwardly recognisable under an applicable bilateral treaty or under the New York Convention.

What distinguishes the more recent wave of decisions from earlier practice is the courts' engagement with the European proceedings not merely as background fact but as a live procedural variable. In at least several documented instances, the question of whether European freezing orders had been granted — and whether they remained in force — was raised by the court itself during case management hearings, and factored into the court's approach to interim relief applications and, in some instances, to the sequencing of enforcement steps. This is a meaningful development: Russian courts have not historically treated the status of foreign proceedings as relevant to their own procedural decisions on cross-border asset recovery.

If you are coordinating a cross-border asset recovery matter with a Russian component, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The judicial positions emerging from these matters do not represent a unified doctrine — Russian courts have not articulated a formal framework for coordinating with European proceedings in asset recovery cases, and the published reasoning across decisions varies considerably. That said, several consistent themes are visible.

First, Russian courts have generally been prepared to acknowledge European interim relief in the reasoning for their own interim measures decisions, treating a subsisting European freezing order as a relevant — though not determinative — factor when assessing the risk of asset dissipation. This does not mean the courts consider themselves bound by the European order; they plainly do not. However, the existence of a foreign measure appears to reinforce the factual picture of dissipation risk, which is otherwise a relatively high bar under Russian civil procedure.

Second, in matters where the foreign claimant's counsel had structured the Russian proceedings to run in parallel with, rather than sequentially after, the European enforcement steps, courts showed a greater willingness to engage with the full evidentiary picture — including documentation produced in the foreign jurisdiction. The practical implication is that parallel coordination, handled with care and with consistent factual framing across both jurisdictions, is more likely to produce a coherent result than a sequential strategy in which the Russian proceedings are filed only after the European process has concluded or stalled.

Third — and this is the point that most directly affects how foreign law firms should brief local counsel Russia — the courts' approach to service, standing, and evidentiary standards for offshore asset Russia tracing has remained technical and strict. Procedural defects at the point of filing continue to generate delays that are difficult to recover from, irrespective of the substantive merits of the claim. This is an area where early and detailed coordination between instructing foreign counsel and Russian lawyers remains essential.

"The coordinating question in these matters is no longer purely legal — it is logistical: which step, in which forum, on what timeline, produces the best aggregate outcome for the claimant." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For partners at foreign firms with clients in active cross-border asset recovery situations involving Russian assets, three practical points follow from this developing judicial practice.

First, the case for early instruction of local counsel has strengthened. The decisions described above reward early procedural preparation — specifically, the identification of Russian-held assets and the drafting of interim relief applications before the European proceedings reach a stage where the factual record has been set in a form that Russian courts may find difficult to use. Instructing Russian lawyers foreign firm partners would engage only after European proceedings are well advanced is a pattern that the recent decisions suggest carries real procedural cost.

Second, consistent factual framing across jurisdictions is now a material strategic consideration, not just a presentational nicety. Russian courts in cross-border asset recovery cases are increasingly willing to look at documentation from foreign proceedings. Where the characterisation of assets, entities, or transactions differs between the Russian filing and the European court record, that inconsistency is likely to be noticed — and it creates unnecessary vulnerability at the hearing stage.

Third, the absence of a bilateral recognition treaty between Russia and most European states means that foreign claimants cannot assume that a European judgment or order will be recognised on its own terms. The Russian proceedings require their own factual and legal foundation. The practical implication is that cross-border asset recovery work involving Russia functions best when treated as a two-track matter from the outset — not as a Russian appendix to a European lead.

For foreign law firms assessing whether and how to coordinate Russia-side enforcement steps, the firm's asset tracing and recovery practice is experienced in providing the kind of structured local counsel support that allows the two tracks to run consistently. Our practice overview at Asset Tracing & Recovery sets out the procedural scope in more detail.

To discuss coordination of Russian and European proceedings — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Regulatory update: cross-border asset recovery in Russia — recent developments
• Foreign creditors and cross-border asset recovery: a practical overview
• Asset Tracing & Recovery — practice area overview

Q: What does this ruling change for foreign creditors pursuing asset recovery in Russia?

A: The decisions described here do not change the statutory framework for cross-border asset recovery in Russia, but they do signal a shift in how Russian courts are engaging with the fact of parallel European proceedings. Courts are treating the existence of foreign interim relief — freezing orders in particular — as a relevant factor in their own interim measures reasoning. For foreign creditors, this means the status of European proceedings should be clearly documented in the Russian filing materials from the outset. Creditors who rely on a European order having already been granted may find it reinforces their interim relief application in Russia, provided the procedural requirements of the Russian filing are met independently.

Q: What should foreign companies do in light of this decision?

A: Foreign companies — or more precisely, their legal advisers — should treat cross-border asset recovery matters involving Russia as two-track from the point of instruction. The practical steps are: first, instruct local Russian counsel before the European proceedings have produced a settled factual record that may not translate cleanly into Russian procedural requirements; second, ensure that asset characterisations and entity descriptions are consistent across the European and Russian filings; and third, do not assume that a European judgment or freezing order will be recognised or enforced in Russia on its own terms. Each track requires its own independent procedural foundation. Firms seeking a local counsel relationship for Russian-side enforcement work may make an enquiry at info@vetrovpartners.com.

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 and recovery practice advises foreign creditors and their international legal counsel on Russia-side enforcement steps in cross-border asset recovery matters, including interim measures applications, parallel proceedings coordination, and offshore asset Russia tracing. With over 1,000 matters handled since inception, the team provides direct partner involvement on every engagement, working alongside instructing foreign counsel throughout the life of the matter.

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/

In a decision handed down by a Russian commercial court in the period under review, the court addressed a question that practitioners advising Emirati creditors with Russian-law claims encounter with some regularity: to what extent may a creditor compel disclosure through corporate registry searches in support of asset tracing against a Russian debtor? The ruling clarified the procedural framework governing such requests and, in doing so, offered the most detailed judicial guidance to date on the evidentiary weight that registry-derived information carries in enforcement proceedings before Russian arbitrazh courts. For foreign law firms coordinating Russian asset tracing instructions on behalf of Gulf-based clients, the decision repays careful attention.

The underlying proceedings arose from a cross-border commercial dispute in which a creditor based in the UAE sought to identify and preserve assets held through a network of Russian legal entities and individual entrepreneurs. The creditor's primary difficulty was one that is familiar to practitioners in this area: the debtor's asset structure was opaque, with participatory interests and real property distributed across several legal persons whose connection to the debtor was not immediately apparent from publicly available information.

To address that opacity, the creditor's Russian counsel applied to the court for a formal order directing the Federal Tax Service to produce extracts from the Unified State Register of Legal Entities (EGRUL) and the Unified State Register of Individual Entrepreneurs (EGRIP) in respect of a defined class of connected persons. The application also sought Rosreestr data on real property holdings. The debtor resisted the application on grounds of proportionality and relevance, arguing that the request amounted to a fishing expedition in the absence of particularised grounds linking the named persons to the creditor's claim.

The procedural question — how specific must a creditor's grounds be before a Russian court will order registry disclosure in aid of asset tracing? — had not previously been resolved with clarity at the appellate level. Earlier first-instance decisions had produced inconsistent outcomes, and practitioners had generally operated on the assumption that courts would require a higher threshold of prior specificity than most foreign creditors could satisfy at the outset of proceedings.

The court granted the application in part. On the threshold question, it held that a creditor is not required to demonstrate, in advance of receiving the registry data, that a particular connected person holds assets of a sufficient value to satisfy the debt. What is required is a reasoned basis — supported by documentary evidence of the commercial relationship and the nature of the claim — for believing that the persons named in the application bear a structural or economic connection to the debtor. Bare assertion, the court confirmed, is insufficient; but a creditor who can produce the underlying transaction documents, evidence of attempts to recover the debt directly, and a reasoned analysis of the debtor's known corporate affiliations satisfies the threshold.

On the scope of disclosure, the court drew a distinction between EGRUL and EGRIP searches, which it treated as categorically less privacy-sensitive and therefore more readily orderable, and Rosreestr property searches in respect of individuals, which it subjected to a proportionality review. The property searches were granted in respect of the debtor entity directly but declined in respect of connected individuals absent more particularised grounds.

"This decision shifts the practical threshold meaningfully in favour of creditors who come to court with well-prepared documentation. For Emirati clients, whose claims often originate in trade finance or commodity supply arrangements, the requirement to produce underlying transaction evidence should be achievable with advance preparation." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The court also addressed the evidentiary status of the registry extracts once produced. It confirmed that registry information constitutes documentary evidence admissible in the substantive enforcement proceedings, rather than merely an investigative step. That characterisation matters: it means that the extracts can be relied upon directly in the creditor's submissions on asset location without the need for a separate evidentiary hearing on authenticity.

If you are advising a client with a cross-border claim against a Russian debtor and need to assess the scope of registry-based disclosure available under Russian procedural law, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms instructing Russian counsel on asset tracing matters, the decision has several practical consequences.

First, the threshold clarification is directly useful for Emirati clients pursuing trade-related claims. UAE-based exporters and commodity traders who have transacted with Russian counterparties on documented terms — letters of credit, supply agreements, or SWIFT-confirmed payment instructions — will typically hold the kind of underlying documentation that the court treated as sufficient to support a registry search application. The key preparation step is assembling that documentation in a form that Russian counsel can present coherently to the court, with a brief explanatory note on the commercial relationship. A well-prepared asset tracing and recovery instruction at the outset materially improves the creditor's position at the disclosure stage.

Second, the distinction between EGRUL/EGRIP searches and Rosreestr property searches for individuals is operationally significant. Creditors and their advisers should expect to obtain corporate registry data relatively readily, but should treat individual property searches as a second stage requiring additional factual development. Sequencing the application accordingly — leading with the entity-level registry searches and using the results to build the particularised grounds for individual property disclosure — is the approach now supported by the court's reasoning. This sequencing strategy is explored in more detail in the firm's practical guide to Russian corporate registry searches and the accompanying legal update on EGRUL and EGRIP searches for foreign creditors.

Third, the admissibility ruling on registry extracts simplifies the evidentiary architecture of enforcement proceedings. Foreign counsel coordinating parallel enforcement steps in the UAE — whether through DIFC courts, ADGM, or onshore UAE courts — should note that Russian registry data can now be obtained through a single procedural step in Russia and relied upon directly in Russian enforcement submissions. That data can then inform, and in some cases support, parallel applications in Gulf jurisdictions where Russian corporate structure evidence is relevant to enforcement or freezing order applications.

The court's analysis does not resolve every open question. Circuit-level variation in how the threshold is applied remains a feature of Russian practice, and practitioners should expect that the position in West Siberian and Ural circuit courts may not track the reasoning of this decision without further appellate endorsement. The firm's matters in the Siberian Federal District have, in recent periods, disclosed a degree of divergence in how local courts approach the proportionality element of registry search applications. Monitoring that divergence is part of the ongoing advisory service the firm provides to foreign counsel with repeat Russian tracing instructions.

To discuss how this ruling applies to a specific enforcement or asset tracing matter involving a Russian debtor — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What does this ruling change about corporate registry searches in Russian asset tracing proceedings?

A: The ruling establishes, at the appellate level, that a creditor does not need to prove in advance that a connected person holds specific assets before the court will order registry disclosure. The operative threshold is a reasoned, document-supported basis for believing that a structural or economic connection exists between the named persons and the debtor. In practice, this means that a creditor who presents the underlying transaction documentation and a coherent analysis of the debtor's known affiliations can obtain EGRUL and EGRIP extracts as a preliminary step in enforcement proceedings, rather than only after asset location has already been established by other means. For Emirati creditors and their advisers, the decision also confirms that registry extracts are directly admissible as documentary evidence, removing one procedural obstacle from the enforcement sequence in Russian arbitrazh courts.

Q: What should foreign companies and their advisers do in light of this decision?

A: Foreign law firms instructing Russian counsel on behalf of Emirati creditors should treat the documentation assembly phase as a priority at the outset of any tracing instruction. The threshold the court endorsed is achievable, but it requires counsel to present the underlying transaction evidence in an organised form alongside a reasoned case for the corporate connections being investigated. Advisers should also note the operational distinction between entity-level registry searches, which the court treated as readily orderable, and individual property searches via Rosreestr, which attract a stricter proportionality review. Sequencing applications accordingly — and budgeting for a two-stage disclosure process where individual assets are in scope — is the practical response to the court's approach. Early engagement with Russian counsel before formal proceedings are issued allows the documentation strategy to be aligned with the court's requirements before the application is filed.

• Russian corporate registry searches for asset tracing: a legal update
• A practical guide to Russian corporate registry searches for foreign creditors
• Asset Tracing & Recovery — practice overview

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 and recovery practice advises foreign creditors — including those based in the UAE and across the Gulf — on registry-based disclosure, asset preservation, and enforcement proceedings before Russian arbitrazh courts. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with direct partner involvement on every engagement. The firm's Novosibirsk base provides direct procedural reach across the Siberian and Ural federal districts, where a material proportion of cross-border enforcement matters against Russian counterparties are heard.

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/

Practitioners advising creditors and claimants with Russian counterparties have long understood that locating assets held through state-adjacent structures is among the most operationally demanding aspects of Russian litigation. In a series of recent decisions, Russian arbitrazh courts have developed a body of judicial practice confirming that the Rosreestr property register — Russia's unified state register of immovable property rights — may be used as a formal investigative instrument against state-related entities, including those whose ownership structures involve federal or regional authorities. This commentary examines the judicial reasoning, the procedural mechanism through which Rosreestr data is obtained and deployed in live proceedings, and the practical implications for foreign litigation counsel instructing Russian lawyers on asset-tracing mandates.

The Rosreestr property register is the authoritative public record of ownership, encumbrance, and restriction over immovable property in Russia. It is administered by the Federal Service for State Registration, Cadastre and Cartography — commonly referred to by its abbreviated institutional name. Entries in the register carry legal conclusiveness: a party recorded as the owner of a Russian property right is treated as such until an entry is amended or challenged through judicial procedure.

For most commercial disputes, access to Rosreestr data is straightforward. Any party — or their counsel — may request an extract from the register on a named property or a named entity's holdings, subject to standard identification requirements. What has been less settled in Russian judicial practice is how that data may be gathered and marshalled when the asset-holding entity is state-related: that is, when the registered owner is a federal or municipal unitary enterprise, a state corporation, a government-controlled joint-stock company, or a regional fund whose beneficial interest traces to a public authority.

The particular difficulty arises because state-related entities in Russia frequently hold assets through layered administrative arrangements — where the formal registered owner may be an entity one or two steps removed from the underlying state budget interest. Foreign creditors and their counsel have historically encountered procedural resistance when seeking to rely on Rosreestr extracts to establish the practical asset picture of such a counterparty: some courts treated broad register searches as disproportionate discovery requests rather than permissible investigative steps within ongoing proceedings.

The decisions examined in this commentary represent a discernible shift in that position. Russian courts operating at first instance and on cassation have confirmed, in at least two distinct procedural contexts, that obtaining a comprehensive Rosreestr property register extract covering an identifiable state-related entity's assets constitutes a legitimate step in the pre-judgment and post-judgment investigative process — not a collateral intrusion into state administrative affairs.

The decisions arose in proceedings where claimants sought enforcement measures — including interim asset freezes under Russian civil procedural rules — against respondents whose property was registered in the name of state-affiliated entities. In each case, the claimants applied to the arbitrazh court for assistance in obtaining Rosreestr data covering the full immovable property portfolio of the respondent entity, including assets registered in multiple regions of the Russian Federation.

The courts confirmed three consequential propositions.

First, the rosreestr property register Russia functions as an investigative tool in the hands of the court, not only as a passive public archive. When a claimant demonstrates that an entity against which enforcement or interim relief is sought holds — or may hold — immovable assets, the court is competent to direct that a comprehensive register extract be obtained and disclosed in the proceedings. This confirmation is significant because it places Rosreestr searches within the formal evidentiary framework of the case rather than outside it.

Second, state-related entities in Russia do not attract a categorical exemption from this process. The courts expressly declined to treat government-controlled ownership as a reason to restrict the investigative reach of the register. The reasoning in the decisions drew on the principle that registration in the state unified property register confers publicly cognisable rights — and that the public character of those rights, not their connection to state authority, is what renders them accessible through judicial process. As the court framed it in one decision, the registration system exists precisely to make property rights transparent and enforceable.

Third, the geographic scope of the Russian asset freeze or investigative disclosure order need not be confined to the jurisdiction of the court handling the main dispute. A court in one federal district may direct that Rosreestr data be obtained across multiple regions, provided that the subject entity has a sufficiently clear connection to the proceedings before it.

"Russian courts have removed the informal assumption that state-linked ownership creates a de facto procedural shield — Rosreestr register data is now confirmed as accessible for enforcement purposes even when the registered owner is a government-controlled entity." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

If you are advising a client with enforcement proceedings against a state-related entity in Russia, early confirmation of the Rosreestr investigative mechanism is material to case strategy. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms instructing Russian counsel, the significance of this judicial development is primarily strategic and procedural, rather than substantive. The underlying ownership rules have not changed. What has changed — or more precisely, what has been clarified — is the procedural posture that Russian courts will adopt when a claimant asks them to use the register actively in aid of the claim.

Several practical implications follow.

Asset-tracing instructions should be scoped more broadly from the outset. Where a Russian counterparty has any state-related ownership dimension — partial state shareholding, a founding authority that is a regional government, or a board composition reflecting public control — counsel should treat the Rosreestr property register as an investigative tool in Russia that is available in principle from the moment proceedings are commenced. Earlier mandates frequently deferred this step, assuming resistance would not be worth the procedural cost. That assumption has been displaced.

Interim relief applications are more viable against state-adjacent counterparties than prior practice suggested. A demonstrated connection between the Rosreestr data and the relief sought — for example, showing that identifiable real estate assets would be accessible for execution — can now support a well-founded interim freeze application. Foreign creditors and their counsel should ensure that Rosreestr searches form part of the pre-application evidential package, not a subsequent step.

Regional diversity of assets matters. The confirmation that a single court may direct multi-regional Rosreestr disclosure reduces the administrative burden that previously attached to asset-tracing exercises involving entities with nationwide property holdings. This is material for major state corporations and federal unitary enterprises, whose asset portfolios can span dozens of cadastral regions.

Foreign counsel coordinating multi-jurisdictional enforcement matters should note the interface between Rosreestr-based tracing and asset-freeze orders in other jurisdictions. For matters where enforcement is pursued in parallel — including in EAEU member states and CIS jurisdictions that maintain analogous property register systems — the Russian judicial approach now described can support a coherent multi-jurisdictional strategy. The firm's Asset Tracing & Recovery practice has experience coordinating precisely this kind of cross-register enforcement.

For background on the Ministry of Finance's position on Rosreestr data access, see our earlier analysis: Ministry of Finance issues guidance on Rosreestr data access. For a broader discussion of the register as an investigative instrument, see Rosreestr property register as an investigative tool in Russia.

Foreign claimants unfamiliar with the practical constraints of asset identification against Russian law state-related entities should consult our Matters page for representative case experience.

Q: What does this ruling change?

A: Prior to this line of judicial decisions, there was a material risk that Russian arbitrazh courts would treat comprehensive Rosreestr register searches against state-related entities as procedurally disproportionate — effectively limiting claimants to information the defendant chose to disclose. The rulings confirm that the register is an active judicial investigative tool accessible in proceedings, and that state-linked ownership does not create an exemption from its use. For foreign creditors and litigation counsel, this changes the risk calculus on interim freeze applications and post-judgment enforcement steps where the counterparty is government-controlled or government-affiliated.

Q: What should foreign companies do in light of this decision?

A: Foreign companies and their advisers with live or anticipated claims against Russian state-related entities should revisit their asset-tracing strategy in light of this development. Specifically: (1) instruct Russian counsel to obtain a comprehensive Rosreestr property register extract at the earliest procedural stage; (2) consider whether the extracted data supports an interim freeze application, including across multiple Russian regions; and (3) where enforcement is pursued in parallel jurisdictions — including EAEU member states — ensure that the Russian judicial findings are coordinated with local counsel's asset-identification steps. A preliminary assessment of the investigative options available under Russian law state-related entities framework can be arranged through the firm.

• Ministry of Finance issues guidance on Rosreestr data access
• Rosreestr property register as an investigative tool in Russia
• Asset Tracing & Recovery practice overview

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 claimants, and their legal counsel on locating, freezing, and recovering assets held through Russian corporate and administrative structures. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with direct partner involvement on every engagement.

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

For foreign litigation counsel requiring a confirmed Russian counsel relationship on asset-tracing matters against state-related entities — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

A Russian arbitrazh court recently examined whether a Turkish trade creditor could compel disclosure of a Russian debtor's bank accounts and financial flows as part of enforcement proceedings — and the procedural approach the court adopted carries practical implications that extend well beyond this particular dispute. For foreign law firms advising Turkish clients with Russian counterparty exposure, the ruling touches directly on the information-gathering tools available at the enforcement stage. Tracing bank accounts and financial flows in Russia follows a distinct procedural logic, one that differs materially from disclosure regimes in civil-law jurisdictions in continental Europe, and understanding how Russian courts frame the creditor's evidentiary burden is essential preparation for any enforcement mandate in this jurisdiction.

Turkey and Russia maintain a substantial volume of bilateral commercial activity — in construction, energy supply, trade in goods, and services — and Turkish trade creditors holding unsatisfied Russian judgments or arbitral awards are a recurring client type for Russian enforcement counsel. The procedural difficulty these creditors face is predictable: a Russian debtor's bank account information and financial flows are not publicly accessible. Unlike some civil-law jurisdictions where enforcement officers hold direct inquiry powers over banking institutions, Russia's procedural framework places the initial information burden on the creditor.

In the matter under review, a Turkish corporate creditor had obtained a judgment against a Russian counterparty and sought to enforce it through the Russian arbitrazh court system. The creditor's difficulty was identifying which Russian credit institutions held accounts in the debtor's name and, beyond account identification, establishing what flow of funds had passed through those accounts — information material to establishing transferable assets and, potentially, to a subsequent challenge of preferential or suspect transactions. The creditor applied to the court for assistance in directing banks and relevant state registries to disclose account information and transaction records. The debtor resisted, raising procedural objections to the scope of the application and to the creditor's standing to make it at that stage of proceedings.

The case turned on two distinct questions: first, whether a judgment creditor — as opposed to an insolvency administrator — held sufficient procedural standing to request court-ordered bank account tracing in Russia; and second, what standard of specificity Russian courts require before ordering financial institutions to disclose transaction data to a foreign creditor.

The arbitrazh court upheld the creditor's application in material part. On standing, the court confirmed that a judgment creditor in post-award enforcement proceedings holds procedural standing to request judicial assistance in identifying debtor assets, including bank accounts and financial flows, without first needing to initiate insolvency proceedings. This is a meaningful confirmation. In practice, many foreign creditors — and their initial advisers — have assumed that bank account tracing in Russia is available only once a debtor has entered formal insolvency, at which point an administrator holds the information-gathering power. The ruling clarifies that the arbitrazh enforcement track provides its own pathway.

On the specificity standard, the court drew a distinction between a generic asset disclosure order and a targeted financial flow tracing request. A bare request to identify "all accounts held by the debtor" was treated by the court as insufficiently particularised — the creditor is expected to identify at least the category of credit institution and, where possible, the approximate period of transactions under examination. The court did, however, accept a tracing application that specified the debtor's known principal banking relationships and a defined transaction window, and ordered the relevant institutions to produce account existence confirmations and transaction summaries within that window.

The cross-border dimension was addressed directly. The debtor argued that because the creditor was a Turkish entity, the court should apply heightened scrutiny to the disclosure request on reciprocity grounds. The court declined this reasoning, holding that Russian civil procedure does not condition enforcement assistance on bilateral reciprocity in the absence of a specific treaty provision to that effect. For Turkish creditors in particular, this is operationally significant: the absence of a Russian-Turkish enforcement treaty does not of itself create a procedural obstacle to asset-tracing assistance at the arbitrazh court level.

"The decision makes clear that arbitrazh courts will support targeted financial tracing requests from foreign judgment creditors — but the application must be constructed with precision. A well-drafted request that specifies the evidentiary purpose and transaction window is materially more likely to succeed than a broad fishing expedition." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

If you are advising a Turkish creditor with an unsatisfied Russian judgment and need to assess the tracing options available, our asset tracing and recovery practice can review the procedural position and assist with application drafting. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign law firms whose clients hold Russian counterparty exposure — whether Turkish or from other jurisdictions with significant Russia trade — this ruling reinforces several practical considerations that should inform how enforcement mandates are structured from the outset.

First, the information-gathering stage matters before the enforcement application is filed. The court's specificity requirement means that a creditor who arrives at the tracing application with only the debtor's registered name and OGRN number is likely to face resistance. Effective pre-application preparation involves identifying the debtor's likely banking relationships from publicly accessible sources — VAT registration data, counterparty documents exchanged during the commercial relationship, payment records — and using that foundation to frame a targeted application. Russian counsel with experience in asset tracing should be engaged at this stage, not after a generic application has already been rejected.

Second, the standing confirmation matters for creditors who have been advised to pursue insolvency as the default route to financial information. Insolvency in Russia is a creditor-side tool with its own timeline and cost structure, and initiating it primarily to access bank account data is often disproportionate. The ruling confirms that the arbitrazh enforcement track — using the court's own procedural powers to compel disclosure — is a viable and considerably faster alternative for creditors whose primary objective is tracing and enforcing rather than restructuring a debtor's affairs.

Third, the reciprocity point has direct relevance to firms advising clients from jurisdictions that lack bilateral enforcement treaties with Russia. The court's reasoning suggests that the absence of a treaty does not independently impair a creditor's access to court-ordered tracing tools. The debtor's bilateral-reciprocity argument, which is sometimes raised by Russian respondent counsel as a tactical objection, was squarely rejected here. Instructing counsel should be prepared to address this argument at the outset and, where necessary, to present the court with the applicable framework under Russian civil procedure.

The Asset Tracing & Recovery (/practices/asset-tracing-recovery/) practice at Vetrov & Partners has acted for foreign trade creditors — including those from EAEU-adjacent jurisdictions — in tracing applications before Russian arbitrazh courts. Related analysis on Russian Supreme Court clarification on asset-tracing procedure is available at Russian Supreme Court clarification on tracing (/insights/atr-lu-003-russian-supreme-court-clarification-on-tracin/), and a broader procedural guide to navigating financial flow tracing in Russia is set out at Navigating tracing bank accounts and financial flows in Russia (/insights/atr-pb-003-navigating-tracing-bank-accounts-and-financia/).

• Russian Supreme Court clarification on tracing (/insights/atr-lu-003-russian-supreme-court-clarification-on-tracin/)
• Navigating tracing bank accounts and financial flows in Russia (/insights/atr-pb-003-navigating-tracing-bank-accounts-and-financia/)
• Asset Tracing & Recovery — practice overview (/practices/asset-tracing-recovery/)

Q: What does this ruling change for foreign creditors seeking to trace bank accounts in Russia?

A: The ruling confirms two points that were previously uncertain in practice. First, a foreign judgment creditor holds procedural standing to request court-ordered bank account tracing in Russian arbitrazh enforcement proceedings without first initiating formal insolvency against the debtor. Second, the court will entertain a targeted financial flow tracing application — covering a specified period and known banking relationships — but is unlikely to grant an unparticularised request for all accounts. For foreign law firms structuring enforcement mandates, this means the information-gathering strategy should be built into the engagement from the outset, not treated as a post-award afterthought.

Q: What should foreign companies do in light of this decision?

A: Foreign companies — and the law firms advising them — that hold unsatisfied Russian judgments or arbitral awards against Russian debtors should review whether a targeted tracing application is feasible before defaulting to an insolvency filing or abandoning enforcement. The practical preparation involves collating any payment records, contract documents, or registration information that identifies the debtor's principal banking relationships, then instructing Russian enforcement counsel to assess whether the available material meets the specificity threshold the court applied. Turkish clients in particular may also wish to note that the bilateral reciprocity argument raised by Russian debtors has been rejected, removing one commonly deployed procedural objection.

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

The firm's asset tracing and recovery practice advises foreign trade creditors, institutional investors, and foreign law firms acting as instructing counsel in tracing and enforcement proceedings before Russian arbitrazh courts. The practice covers pre-application asset identification, court-ordered disclosure, and cross-border coordination with creditor-side counsel across multiple jurisdictions. With over 1,000 matters handled since inception, the team provides direct partner-level involvement from the first assessment through to enforcement completion.

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

For an initial review of tracing and enforcement options against a Russian debtor — including for Turkish and other foreign creditors — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

In advising creditors with Russian-linked exposures, one pattern recurs across instructions from Turkish law firms: the assumption that a multi-layered shell structure assembled outside Russia will insulate a debtor's Russian assets from judgment creditors. A line of decisions from Russian commercial courts — arbitrazh courts — has tested that assumption, with results that foreign counsel instructing Russian lawyers need to understand before initiating or recommending a recovery strategy.

Turkish trade relationships with Russia have grown substantially over recent years, driven by a combination of geography, EAEU-adjacent supply chains, and bilateral commercial ties. Where those relationships have soured — through non-payment, fraudulent misrepresentation, or outright asset stripping — Turkish creditors often discover that the Russian counterparty has placed its principal assets behind one or more intermediate holding entities: companies incorporated outside Russia, typically in jurisdictions offering nominee ownership or bearer-share structures, but whose underlying assets — real estate, receivables, equipment, or shares in Russian operating companies — remain squarely within Russian jurisdiction.

The scenario that generated the decision discussed here involved a Turkish trade creditor holding a commercial arbitration award against a Russian-linked obligor. Enforcement attempts revealed that the direct obligor was an empty vessel: its assets had been transferred to a related entity incorporated in a third country, which in turn held shares in a Russian operating company. The creditor, instructed a Russian counsel to pursue the Russian assets directly, arguing that the interposed structure should be disregarded. The case raised a question that Russian courts have answered inconsistently until recently: on what basis, and under what procedural framework, can a Russian arbitrazh court pierce through or disregard a foreign corporate layer to reach assets in Russia?

The court held that where a foreign intermediate entity is demonstrably devoid of independent commercial activity — no separate management, no staff, no operational purpose beyond asset-holding — and where the timing of asset transfers to that entity coincides with the emergence of the creditor's claim, the interposition does not create a genuine jurisdictional barrier to enforcement in Russia. The court applied the concept of economic ownership alongside Russia's sham-transaction doctrine, treating the series of transactions through which assets were moved as a single artificially disaggregated transfer. Russian insolvency legislation contains provisions allowing the reversal of preferential and suspicious transactions; but in this matter the court reached a comparable outcome in a non-insolvency enforcement context by deploying broader civil-law principles of bad-faith dealing.

"[The court's reasoning confirms what practitioners have observed for several years: Russian commercial courts are increasingly willing to look through formal corporate structure where the economic reality is plainly different, and to apply that analysis across jurisdictional lines." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners]

Two features of the decision are particularly significant. First, the court did not require the creditor to initiate winding-up proceedings against the Russian operating company or to establish insolvency — the enforcement route remained a civil claim. Second, the court accepted evidence of the foreign shell's nominal existence in documentary form: corporate registries, bank account statements showing inactivity, and a pattern of intra-group transfers timed to pre-empt enforcement. This evidential threshold — substantial but not prohibitive for a well-prepared creditor — represents the operative standard for counsel planning a similar strategy.

If you are advising a Turkish client on enforcing against Russian-linked assets, we are available to discuss procedural strategy and evidence mapping as instructing counsel — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For Turkish law firms and foreign counsel more broadly, this decision recalibrates the risk calculus around shell-structured Russian exposures in three respects.

First, the forum question. Russian arbitrazh courts — not Turkish courts, not international arbitration tribunals — are the operative forum for enforcing against assets physically located in Russia. Where the debtor has structured its affairs through a foreign shell, the Russian court's willingness to look through that structure is the critical jurisdictional fact. Counsel should not assume that a foreign judgment or award against the shell entity will translate automatically into enforcement against the Russian assets; a separate Russian enforcement proceeding, properly constructed, is typically required. The Asset Tracing & Recovery practice at Vetrov & Partners regularly acts as instructed Russian counsel in exactly this configuration.

Second, the evidence question. The court's approach privileges economic substance over legal form. For foreign counsel preparing instructions, this means that the pre-litigation evidence-gathering phase is not a preliminary formality — it is the substance of the case. Corporate registry searches, banking correspondence, transfer documentation, and the chronological relationship between asset movements and the creditor's emerging claim are all material. Where Turkish creditors have conducted their own preliminary investigations, those materials should be shared with Russian counsel at the outset. See also our related analysis of legislative amendments affecting the unwinding of shell company structures in Russia and our practitioner overview of shell company unwinding with Russian elements for the broader framework within which this decision sits.

Third, the timing question. The court's reasoning treated the temporal relationship between asset transfers and creditor exposure as central. Creditors who allow significant time to pass between discovering a fraudulent transfer and initiating Russian proceedings give debtors the opportunity to conduct further restructuring, move assets within Russia, or initiate voluntary insolvency proceedings that alter the available remedies. Instructions to Russian counsel should be given as early as the creditor's own analysis permits.

For matters of this nature documented in our practice, the firm has acted as Russian counsel coordinating with Turkish and other foreign law firms on evidence strategy, procedural sequencing, and the relationship between foreign arbitration outcomes and Russian enforcement steps.

• Legislative amendments affecting the unwinding of shell company structures in Russia
• Unwinding shell company structures with Russian elements: a practitioner overview
• Asset tracing and recovery in Russia: an overview for foreign creditors

Q: What does this ruling change for foreign creditors pursuing Russian-linked assets through shell structures?

A: The ruling confirms that Russian arbitrazh courts will apply an economic-substance analysis to interposed foreign entities and, where those entities lack genuine independent activity, will treat the underlying Russian assets as reachable without requiring a separate insolvency filing. The practical change is one of procedural pathway: creditors who previously assumed enforcement required winding up the intermediate entity in its home jurisdiction can now pursue a direct civil claim in Russia, provided they can demonstrate the shell's absence of real economic activity and the bad-faith timing of the asset transfers. This is a meaningful shift from the earlier, more formalistic approach some circuit courts had applied.

Q: What should foreign companies and their advisers do in light of this decision?

A: Foreign counsel advising Turkish or other creditors with Russian-linked exposures should take three immediate steps. First, assess the corporate structure of the debtor and its affiliates to identify any interposed entities and the assets they hold in Russia. Second, secure all available evidence of asset transfers — timing, value, and intra-group relationships — before initiating any Russian proceedings, since this evidence is central to the court's economic-substance analysis. Third, instruct Russian counsel with experience in non-insolvency enforcement against structured entities before limitation periods in Russia begin to run. Early instruction allows counsel to advise on forum, interim measures, and the coordination of any parallel foreign proceedings.

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 — including Turkish trade creditors and institutional investors — on recovering assets located in Russia through civil enforcement, sham-transaction claims, and coordinated cross-border proceedings. The team acts as instructed Russian counsel for foreign law firms, providing procedural strategy, evidence mapping, and court representation across Russian commercial courts.

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

To discuss instructions on a Russian enforcement matter involving shell-structured assets, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

In a pattern that has consolidated markedly since 2022, Russian arbitrazh courts have been willing to look through Cyprus-registered holding structures and pursue individual debtors directly — treating the Cyprus intermediate layer as a transparent screen rather than a liability break. For foreign creditors and the counsel instructing them, this development substantially changes both the enforcement calculus and the range of recoverable assets in cross-border Russian matters.

For decades, the Cyprus-Russia corporate structure was the default architecture for Russian private capital seeking European legal form. A Russian operating company would be owned — directly or through further intermediaries — by a Cyprus-registered holding vehicle, which in turn was controlled by one or several individual beneficial owners. The arrangement offered familiar advantages: treaty-based withholding tax rates, relative ease of corporate governance documentation, and a degree of separation between the operating business and its ultimate controller.

Post-2022, the legal assumptions underlying that architecture shifted. Russia's suspension of its double taxation treaty with Cyprus — effective August 2023 — removed the primary fiscal rationale for the structure. More directly relevant to asset recovery practitioners, Russian courts began scrutinising the holding layer in the context of enforcement and insolvency proceedings, particularly where the individual beneficial owner remained resident in Russia or held Russian assets alongside the offshore holding.

The pattern explored in this note concerns a category of cases where arbitrazh courts have examined Cyprus-Russia corporate structures and considered whether the individual standing behind the holding company should be treated as a co-debtor, a controlling person, or a party whose personal assets are reachable through subsidiary liability mechanisms available under Russian insolvency and civil legislation.

Firms instructing Russian counsel on cross-border enforcement matters involving Cyprus-Russia corporate structures may benefit from an early-stage assessment of the individual debtor angle — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The decisions that define this trend share a common analytical structure. In each case, the court did not simply apply a standard corporate veil analysis. Instead, it drew on Russian civil legislation's provisions for controlling-person liability — a domestic doctrine that has developed substantially since the early 2010s through insolvency proceedings — and applied it to the relationship between the Cyprus holding entity and the individual who directed its activities.

The key findings in the most instructive decisions are these. First, courts treated the Cyprus entity's formal legal separateness as immaterial where the evidence established that the individual made all commercially significant decisions for both the Cyprus holding and the Russian operating subsidiary. The registration in Nicosia was characterised as an organisational convenience, not a substantive separation of legal personality. Second, courts identified the absence of independent management at the Cyprus level — no resident director with genuine authority, no local substance — as a basis for attributing the Cyprus entity's obligations directly to the individual.

Third, and most significant for enforcement practitioners, courts made findings linking the individual's personal assets — including Russian real estate, bank accounts, and participatory interests in other Russian entities — to the liability chain running through the Cyprus structure. This is not a full disregard of corporate form in the traditional sense. Russian courts have been careful to frame the analysis in the language of controlling-person liability and bad-faith conduct, rather than in common law piercing-of-the-veil terms. The practical effect, however, is substantively similar: the individual's Russian-sited assets become part of the enforcement landscape.

"The turn in Russian arbitrazh practice is not a simple veil-piercing import from common law. It is a domestic doctrine — controlling-person liability — applied with increasing precision to cross-border holding arrangements." — Elizaveta Razina, Senior Lawyer, Practice Lead — Asset Tracing & Recovery, Vetrov & Partners

Asset freeze applications — interim measures targeting individual debtors' Russian assets — have accompanied these proceedings in a number of documented matters, and courts have in several instances granted them at an early stage before the liability question was resolved on the merits. This reflects a broader willingness in Russian arbitrazh practice to preserve the enforcement position pending substantive determination.

For the full picture of how Russian courts approach Cyprus-Russia corporate structures analytically, see our related analysis: How Russian courts approach Cyprus-Russia corporate structures.

The practical implications divide along two axes: offensive (for creditors seeking to recover) and defensive (for those advising on existing structures that may be challenged).

For creditors and their counsel, the trend enlarges the addressable asset pool in Russian enforcement proceedings. Where a Cyprus-Russia corporate structure is in the recovery chain, the individual beneficial owner's Russian assets — not merely the holding company's participatory interest in the Russian subsidiary — may now be within scope. The procedural gateway is a subsidiary liability claim or a controlling-person liability application, both of which require demonstrating the individual's decision-making role. Evidence of this kind is often available through publicly filed corporate documentation, prior litigation records, and the forensic analysis of corporate governance arrangements.

For counsel advising foreign clients who hold Russian assets through Cyprus structures — or who are themselves the individual debtors in potential future proceedings — the implications are defensive. The decisions signal that substance requirements for the Cyprus layer are no longer a theoretical concern. An intermediary holding company without genuine governance autonomy, operational substance, or resident management is structurally vulnerable to the liability attribution analysis that Russian courts have now applied in a number of cases.

Foreign law firms engaged in asset tracing and recovery matters involving Russian counterparties should treat the individual-debtor angle as a standard item in the initial case assessment — not an optional refinement. The trend documented here is consistent with the broader enforcement trajectory visible in related Russian court practice: see also Roskomnadzor enforcement trends and Cyprus-Russia structures for adjacent regulatory context.

For foreign creditors who have already obtained judgments or awards and are seeking to enforce against a Russian-based individual, the asset tracing phase should map not only the debtor's direct Russian holdings but also the participatory interests and real property held through or alongside the Cyprus structure. The Matters section of this website provides anonymised illustrations of how such enforcement exercises have been structured in practice.

If you are advising a client with Russian exposure through a Cyprus-Russia corporate structure — or seeking to enforce against an individual debtor in Russia — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• How Russian courts approach Cyprus-Russia corporate structures
• Roskomnadzor enforcement trends and Cyprus-Russia structures
• Asset Tracing & Recovery — practice overview

Q: What does this ruling change for foreign creditors pursuing individual debtors in Russia?

A: The decisions confirm that Russian arbitrazh courts will, in appropriate circumstances, attribute the liabilities of a Cyprus holding entity to the individual who controlled it — using domestic controlling-person and subsidiary liability mechanisms rather than a general corporate veil doctrine. For foreign creditors, this means the individual beneficial owner's Russian-sited assets may be within the scope of enforcement proceedings, provided the creditor can establish the individual's decision-making role and the absence of genuine substance at the Cyprus level. The change is not absolute — each case turns on its facts — but the analytical framework is now well-established in Russian arbitrazh practice.

Q: What should foreign companies do in light of this decision?

A: Foreign clients advising individuals who hold Russian assets through Cyprus intermediaries should commission a structural review that assesses the substance of the Cyprus layer and the governance arrangements between the holding entity and the Russian operating company. Where the substance is thin, restructuring options should be considered before enforcement proceedings are commenced. For creditors, the priority is an early-stage asset mapping exercise that includes the individual debtor's Russian holdings alongside the corporate structure, and a liability attribution analysis to determine whether a controlling-person claim is viable on the available evidence.

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

The firm's asset tracing and recovery practice advises foreign creditors, foreign law firms, and institutional claimants on the enforcement of claims against Russian-based debtors — including matters involving Cyprus-Russia holding structures and individual beneficial owner liability. With over 1,000 matters handled since inception, the team combines procedural expertise across Russian arbitrazh courts with 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/

Among the recurring questions from foreign law firms instructing us on Russian enforcement matters, one has become increasingly prominent over the past two years: can UAE real estate owned by a Russian national debtor be reached through Russian enforcement proceedings? A recent line of arbitrazh court decisions provides a more structured answer than practitioners had previously enjoyed — and the answer, in short, is that Article 46 of Law 229-FZ creates a meaningful, if procedurally demanding, pathway. For foreign counsel coordinating cross-border recovery strategies, understanding precisely how Russian courts have reasoned through this question is now essential.

When a Russian national debtor holds real estate in the UAE — typically in Dubai or Abu Dhabi — a foreign creditor with a Russian court judgment or arbitral award faces an immediate structural difficulty. UAE real estate is not visible to the Russian bailiff service through domestic asset registries. It does not appear in standard enforcement database searches. In the ordinary course, a bailiff confronted with an unlocatable asset will issue an act confirming the temporary impossibility of enforcement under Russian enforcement legislation, suspending active enforcement and returning the writ to the creditor.

For years, this procedural reality was treated by many practitioners as a dead end in the Russian leg of any cross-border recovery strategy. The conventional approach was to shift focus entirely to the UAE — seeking independent proceedings before the Dubai courts or the DIFC — without attempting to develop the Russian enforcement angle further.

What changed is that creditors and their counsel began to probe the enforcement framework more systematically. In a series of proceedings before Russian arbitrazh courts, creditors raised a specific question: does the issuance of an act under Article 46 of Law 229-FZ — the provision governing the temporary return of an enforcement writ where assets cannot be identified — preclude a creditor from taking further steps within the Russian system to compel disclosure of foreign-held assets, or to place formal constraints on a debtor's capacity to deal with those assets? The courts' engagement with that question is the subject of this commentary.

In a pattern of decisions — handed down, in the main, over the past eighteen months — Russian arbitrazh courts have addressed the scope of creditor rights at the intersection of domestic enforcement proceedings and offshore asset-holding by Russian national debtors. The courts have generally held that the issuance of an act under Article 46 of Law 229-FZ does not foreclose all creditor action within the Russian enforcement framework. Rather, it represents a procedural milestone that resets the creditor's position without extinguishing substantive rights.

Several points of reasoning have recurred across these decisions and are worth recording for practitioners working at this interface.

First, Russian courts have held that a creditor retains the right to re-present an enforcement writ to the bailiff service after the Article 46 act is issued — and to use successive re-presentations to maintain enforcement pressure, including by requesting that the bailiff formally direct disclosure inquiries to relevant Russian-side financial institutions where the debtor maintains correspondent relationships or accounts. This is procedurally modest, but it keeps the enforcement record live.

Second, and more significantly for offshore-asset cases, courts have addressed the creditor's ability to seek judicial measures — including prohibitory orders — targeting a debtor's capacity to deal with identified foreign assets. Where a creditor can provide the court with evidence that the debtor holds specific real estate in the UAE (through title registry extracts, notarial records, or open-source UAE land department data), Russian arbitrazh courts have, in some circuits, been willing to consider measures that restrict the debtor's ability to transfer, encumber, or otherwise dispose of those assets under Russian law — even though direct enforcement against the UAE property must ultimately proceed through UAE channels.

Third, courts have engaged — with varying results — with the argument that concealment of foreign assets in the context of enforcement proceedings may engage separate legal consequences for the debtor under Russian law, creating additional pressure points for a creditor pursuing a multi-jurisdictional strategy.

"The Article 46 pathway in Russian enforcement proceedings is more than a procedural impasse — recent arbitrazh court decisions show it can be used to construct a documented enforcement record that strengthens the creditor's position when parallel proceedings are opened in the UAE." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign law firms advising creditors with Russian judgment debtors holding UAE property, early engagement with the Russian enforcement leg — even where direct asset realisation is not immediately achievable — can shape the creditor's strategic position materially. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For a foreign law firm advising a client with a Russian court judgment or arbitral award against a Russian national who holds UAE real estate, these decisions reframe the Russian enforcement leg in two important ways.

The first is evidentiary. The procedural record generated by pursuing enforcement under Article 46 of Law 229-FZ — including the bailiff's formal acts, the correspondence with financial institutions, and any judicial orders obtained — can serve as a body of evidence in UAE proceedings. Dubai courts and DIFC tribunals, when assessing the creditor's diligence and the debtor's conduct, may have regard to documented enforcement efforts in the debtor's home jurisdiction. A well-maintained Russian enforcement file is, in this sense, a document production asset in the parallel proceeding.

The second is tactical. Where a debtor understands that the Russian proceedings remain technically live and that a creditor can re-present the writ, there is an ongoing cost to non-resolution — both in terms of reputational exposure through public enforcement records and in terms of the constraints that Russian judicial prohibitory measures may place on asset management. This is most relevant for debtors who retain Russian business interests alongside UAE holdings, since the Russian enforcement framework can be used to apply targeted friction without requiring cross-border asset transfer or enforcement at the UAE level.

Practitioners coordinating multi-jurisdictional recovery efforts should note that the evidentiary and tactical value of the Russian enforcement leg is circuit-dependent. Courts in some federal districts have been more receptive than others to creditor applications for prohibitory measures targeting offshore assets. Local counsel familiar with the relevant circuit's current practice is not an optional engagement — it is a prerequisite for calibrating what the Russian leg can and cannot achieve.

The firm's Asset Tracing & Recovery practice has acted in matters involving the coordination of Russian and UAE enforcement proceedings and can advise on the evidentiary requirements for establishing UAE asset-holding within Russian court proceedings.

Further context on the regulatory background to this area is set out in our regulatory update on UAE real estate owned by Russian nationals, and the creditor-side framework is examined in detail in our briefing on foreign creditors and UAE real estate held by Russian nationals.

For a wider view of the firm's cross-border recovery work, the Matters page provides representative anonymised matter descriptions.

If you are coordinating enforcement proceedings that span Russia and the UAE, the firm can assist with the Russian enforcement leg — including preparation of court applications and coordination with UAE counsel. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Regulatory update: UAE real estate owned by Russian nationals
• Foreign creditors and UAE real estate owned by Russian nationals
• Asset tracing and recovery: practice overview

Q: What does this ruling change?

A: The decisions clarify that Article 46 of Law 229-FZ — the provision under which a bailiff returns an enforcement writ when assets cannot be located in Russia — does not end a creditor's enforcement options within the Russian system. Courts have held that the creditor may re-present the writ, seek disclosure-related measures through the bailiff service, and, in some circuits, apply for judicial prohibitory orders targeting identified offshore assets including UAE real estate. The change is one of recognised scope: practitioners who treated the Article 46 act as a terminal event should now revisit that approach and consider whether the Russian enforcement record can be developed further in parallel with UAE proceedings.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors with Russian judgments or awards against Russian national debtors who hold UAE real estate should take three steps. First, ensure that the Russian enforcement file remains active — do not allow the enforcement writ to lapse or the file to close after an Article 46 act is issued. Second, gather and preserve UAE land department records, title extracts, or other evidence of the debtor's specific property holdings in the UAE, since this evidentiary foundation is what Russian courts have required before considering prohibitory measures. Third, engage Russian enforcement counsel early in the multi-jurisdictional strategy rather than as a secondary matter once UAE proceedings are under way — the evidentiary record built in the Russian proceedings can directly support the creditor's position before UAE courts and tribunals.

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 cross-border enforcement strategies involving Russian-held or Russia-connected assets, including matters where enforcement requires coordination across multiple jurisdictions. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of the Russian enforcement framework with 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/

Coordinating enforcement across Russia and foreign jurisdictions has long tested the patience and ingenuity of practitioners on both sides of a cross-border dispute. In matters involving oil and gas assets – where ownership structures are layered, asset registrations span multiple countries, and operational licences are subject to Russian regulatory approval – the coordination problem is sharper still. A recent line of decisions from the Russian arbitrazh courts has addressed, with unusual directness, how enforcement proceedings initiated in a foreign jurisdiction interact with parallel Russian recovery efforts over assets held by the same debtor. For foreign law firms acting as lead counsel or coordinating counsel in such matters, the implications deserve careful attention.

The proceedings arose from a dispute between a foreign trade creditor and a Russian operating company active in the extraction sector. The creditor held a final award from an international arbitral institution and had obtained interim relief in a European jurisdiction over assets held there. Separately, the creditor sought to enforce the same award before Russian arbitrazh courts in respect of Russian-sited assets, including a participation interest in a licence-holding entity and receivables owed to the debtor by domestic counterparties.

The procedural difficulty was not the enforcement of the award itself – Russian courts have an established framework for recognising awards made under the rules of major institutional arbitral bodies. The difficulty was coordination: the creditor's representatives needed the Russian court to take account of interim measures already in place abroad, and to sequence its own enforcement steps in a manner that would not inadvertently prejudice the foreign proceedings or create a double-recovery position.

The debtor's representatives contested the application on procedural grounds, arguing that the existence of parallel foreign proceedings rendered the Russian enforcement application premature and, in the alternative, that certain assets fell outside the scope of permissible enforcement in light of Russian licensing regulation applicable to the extraction sector.

The arbitrazh court rejected the procedural objection. In doing so, it confirmed a principle that practitioners advising creditors with Russian oil and gas exposure will find significant: the existence of parallel foreign enforcement proceedings is not, of itself, a bar to commencing or continuing enforcement in Russia. The two proceedings are treated as addressing distinct pools of assets in distinct jurisdictions, each governed by its own procedural rules.

On the assets question, the court drew a distinction between assets that are subject to regulatory restriction under Russian natural resources legislation and those that are not. The participation interest in the licence-holding entity was found to be subject to restrictions on assignment without regulatory consent. The court declined to make a direct enforcement order against it pending clarification of the regulatory position. Receivables and cash balances held in Russian accounts were treated differently: the court confirmed that enforcement could proceed against those assets without regulatory precondition.

The court also addressed, briefly but materially, the treatment of interim measures obtained abroad. It held that a foreign interim order does not create an obligation on a Russian court to stay or modify domestic enforcement proceedings. However, the court observed that a creditor who obtains recovery in two jurisdictions from the same underlying debt must account for amounts recovered when seeking execution in Russia. The anti-double-recovery principle was acknowledged, even if its application to the specific facts was deferred.

"This decision reflects a pragmatic approach that is consistent with how the better-reasoned arbitrazh decisions have handled cross-border coordination: parallel tracks are permitted, but creditors bear the responsibility for managing sequencing and avoiding double recovery." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

If you are advising a creditor with enforcement proceedings pending in Russia and one or more foreign jurisdictions, an early coordination review can prevent procedural conflicts that are expensive to unwind. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For firms acting as lead or coordinating counsel on cross-border enforcement matters involving Russian oil and gas assets, several practical points follow from this decision.

First, Russian enforcement proceedings can run in parallel with foreign proceedings. There is no requirement to exhaust foreign remedies before commencing in Russia. The arbitrazh courts will assess enforceability against Russian-sited assets on their own terms.

Second, sector-specific regulatory constraints matter. Assets held through licence-holding entities in the oil and gas sector are not simply a subset of general commercial assets for enforcement purposes. Russian natural resources legislation imposes consent requirements on disposals and assignments of interests in licence-holding structures. A creditor whose enforcement strategy targets such interests should expect a regulatory stage. Engaging Russian counsel who understands both the enforcement framework and the licensing regime for the extraction sector is therefore not a stylistic preference – it is a practical necessity.

Third, sequencing across jurisdictions requires active management. The anti-double-recovery principle acknowledged by the court imposes a duty of disclosure on the creditor. Recovery obtained abroad must be reported and accounted for in the Russian proceedings. A firm coordinating enforcement across jurisdictions needs a clear internal protocol for tracking partial recoveries and updating the Russian court accordingly. Failure to maintain that discipline creates an exposure that is difficult to remedy after the fact.

Fourth, interim measures obtained in foreign jurisdictions do not automatically bind Russian enforcement proceedings, but they are not irrelevant. A well-structured enforcement strategy should consider the sequencing of interim applications – in which jurisdiction to seek measures first, and how to present those measures to the Russian court in a way that reinforces rather than complicates the domestic enforcement effort. For further detail on how Russian courts have treated coordination between proceedings, see our analysis of court practice shifts in coordinating enforcement across jurisdictions and the related review of key risk points in coordinating enforcement across Russia.

The broader asset tracing and recovery framework for foreign creditors operating in Russia is discussed on our Asset Tracing & Recovery practice page. For an overview of matters of this nature, see our Matters section.

For law firms advising clients with Russian oil and gas assets subject to enforcement, we are available to discuss coordination strategy and Russian procedural steps at any stage of the proceedings. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What does this ruling change?

A: The decision consolidates and makes more explicit the principle that Russian arbitrazh courts will not defer to parallel foreign enforcement proceedings as a reason to stay or delay domestic enforcement. It also clarifies that oil and gas licence-holding interests are treated as a separate category for enforcement purposes – subject to regulatory consent requirements that do not apply to liquid assets such as receivables and cash. For practitioners, the ruling sharpens the planning question: which assets to pursue in which forum, and in what sequence. It does not create new rights, but it removes some of the uncertainty that previously made creditors hesitant to run parallel proceedings.

Q: What should foreign companies do in light of this decision?

A: Foreign creditors and their advisers should review enforcement strategies that rely solely on recovery in the foreign jurisdiction and treat Russian assets as a secondary option. The decision confirms that Russian proceedings are viable in parallel and need not wait. Where the debtor holds oil and gas sector interests in Russia, the regulatory consent dimension should be assessed at the outset – not after enforcement is already underway. Firms coordinating across jurisdictions should also put in place a formal tracking protocol for partial recoveries, to meet the anti-double-recovery disclosure obligation that Russian courts have now affirmed. Early engagement of Russian counsel who can advise on both the procedural and the sector-specific regulatory aspects is the most effective starting position.

• Court practice shift on coordinating enforcement across jurisdictions
• Key risk points in coordinating enforcement across Russia
• Asset Tracing & Recovery: practice overview

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 and recovery practice advises foreign trade creditors, institutional investors, and foreign law firms acting as coordinating counsel on enforcement proceedings involving Russian-sited assets. The team has handled matters spanning the extractive sector, industrial assets, and financial receivables, combining procedural enforcement expertise with direct knowledge of Russian regulatory frameworks applicable to specific asset classes. With over 1,000 matters handled since inception, partner involvement is maintained 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/

In a decision handed down at cassation level, a Russian arbitrazh court addressed, with unusual directness, the question that foreign counsel most frequently raise when enforcement proceedings over Russian-situated assets are already under way: does a worldwide freezing order obtained abroad constrain the Russian enforcement process? The answer the court gave — and the reasoning supporting it — merits careful reading by any firm that advises creditors holding WFOs and expecting those orders to do practical work inside Russia.

Worldwide freezing orders are a powerful instrument in the hands of English courts and courts in a number of common-law jurisdictions. They bind the respondent personally, wherever assets are located, and they carry extraterritorial reach as a matter of their own jurisdictional logic. In cross-border disputes involving Russian-situated assets, foreign counsel routinely obtain WFOs at an early stage — sometimes before substantive proceedings have concluded — on the basis that the respondent's Russian holdings represent the most readily identifiable pool of recoverable value.

The difficulty arises at the enforcement stage. Russian domestic enforcement proceedings operate on a self-contained procedural track. The bailiff service executes against assets located in Russia on the basis of a domestic writ of enforcement, which is issued by the Russian court in which the creditor's judgment or award has been recognised. Foreign interim orders — including WFOs — do not slot neatly into that system. The question in the case under review was whether a Russian arbitrazh court, once seized of enforcement proceedings, was obliged to take account of a WFO issued by a foreign court against the same respondent over the same pool of assets.

The matter arose in the context of a commercial dispute between a foreign claimant and a Russian company. The claimant held a WFO obtained in a jurisdiction with a well-developed asset-freeze jurisprudence. Separately, the claimant had obtained recognition of a foreign arbitral award in Russia and had initiated enforcement proceedings in the competent Russian arbitrazh court. During those proceedings, the respondent raised the WFO as a basis for challenging enforcement steps taken by the bailiff service, arguing, in effect, that certain asset-disposal restrictions imposed by the foreign order should be treated by the Russian court as independently applicable constraints.

The cassation court declined to treat the worldwide freezing order as having direct operative force within the Russian enforcement proceedings. Its reasoning proceeded in three steps.

First, the court confirmed the established position under Russian civil procedure: foreign court decisions, including interim measures, do not have legal effect in Russia absent a recognised basis for their enforcement — which, in practice, means either a directly applicable international treaty providing for mutual recognition of interim relief, or a specific Russian court order granting recognition. Neither condition was met in the case before it.

Second, the court addressed the argument that the WFO created a personal obligation on the respondent that should, as a matter of comity, be given effect in parallel with the Russian enforcement track. The court acknowledged the doctrine of international comity but held that comity is a principle of judicial conduct, not a freestanding rule of Russian procedural law. In the absence of a statutory or treaty basis, a Russian court acting in enforcement proceedings cannot subordinate its procedural framework to an order it has not been asked to recognise and which has not been recognised.

Third, and most practically, the court made clear that the respondent's reliance on the WFO as a procedural shield — as a basis for staying or disrupting enforcement steps in Russia — was misconceived. The WFO addressed the respondent's own conduct. It did not, by its terms or by operation of Russian law, limit the powers of the Russian bailiff service or the jurisdiction of the Russian enforcement court.

"What this ruling confirms is that a worldwide freezing order, however broadly drafted, cannot substitute for a properly initiated Russian asset-freeze application — the enforcement track in Russia has its own procedural requirements." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For firms advising clients who hold worldwide freezing orders over Russian-situated assets, confirming the procedural position in Russia before enforcement steps are taken is rarely straightforward — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For firms co-ordinating cross-border enforcement that includes a Russian element, the ruling consolidates what has long been the working assumption of experienced Russian practitioners — but resolves a point on which courts below cassation level had not always spoken with one voice.

The most immediate consequence concerns strategy at the outset of enforcement. A WFO will not, of itself, prevent a respondent from dealing with Russian-situated assets once the respondent knows that the Russian court will not treat it as operative. Firms advising creditors should assume that, in parallel with any WFO application abroad, a separate application for interim measures before the competent Russian arbitrazh court is necessary if Russian assets are to be effectively ring-fenced during the enforcement period.

The ruling also has implications for the sequencing of enforcement steps. Foreign counsel sometimes delay Russian enforcement proceedings while awaiting the outcome of foreign litigation or while pursuing an appeal. During that window, without a domestic Russian interim measure in place, the asset pool may move. The cassation court's reasoning removes any residual basis for arguing that a WFO holds the position in Russia pending those delays.

A further point concerns the use of the WFO as a negotiating instrument. In some mandates, the existence of a WFO creates settlement pressure independently of the formal enforcement track. That dynamic is not diminished by this ruling — the WFO retains its force in the jurisdiction that issued it and continues to bind the respondent personally. What the ruling limits is any expectation that Russian enforcement proceedings will be procedurally constrained by the order's existence.

For firms instructing local counsel in Russia as part of a multi-jurisdictional recovery strategy, the practical upshot is this: the Russian enforcement track should be treated as independent and should be resourced accordingly. Co-ordination between the team managing the WFO and the team conducting Russian enforcement proceedings is, in our experience, most effective when it begins at the asset-identification stage — before proceedings in any jurisdiction are commenced.

For more on the recognition framework for foreign interim measures and the procedural pathway for asset-freezing relief in Russia, see our related analysis: Worldwide freezing orders and Russian-situated assets and A practical guide to worldwide freezing orders in Russian-related disputes.

Firms co-ordinating multi-jurisdictional enforcement with a Russian element are welcome to discuss the domestic procedural position in confidence — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Worldwide freezing orders and Russian-situated assets
• A practical guide to worldwide freezing orders in Russian-related disputes
• Asset tracing and recovery in Russia: an overview

Q: What does this ruling change for creditors who already hold a worldwide freezing order over Russian assets?

A: The ruling confirms, at cassation level, the position that a worldwide freezing order issued by a foreign court has no direct operative force within Russian enforcement proceedings unless it has been separately recognised by a Russian court on a treaty or statutory basis. For most creditors holding English-court WFOs, no such basis currently exists. The practical consequence is that a WFO cannot be relied upon to constrain the Russian bailiff service or to stay enforcement steps in Russia. Creditors in this position should seek Russian interim measures independently, either through the arbitrazh court competent for the enforcement proceedings or — where proceedings are not yet commenced — through a pre-claim application for interim relief.

Q: What should foreign companies do in light of this decision?

A: The immediate step is to review the Russian enforcement position separately from the WFO strategy. If Russian-situated assets are material to recovery and no domestic Russian interim measure is in place, the risk of asset dissipation during enforcement proceedings is real. Firms advising creditors should instruct local Russian counsel at the stage when the WFO is being sought, not after. Co-ordination across the jurisdictions involved — including agreement on the sequencing of enforcement steps and the scope of asset-identification work — materially affects outcomes. A preliminary conversation with Vetrov & Partners can help map the Russian procedural options without commitment to a particular strategy.

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

The firm's Asset Tracing & Recovery practice advises foreign creditors, institutional claimants, and foreign law firms on Russian enforcement proceedings, interim measures, and cross-border asset recovery. With over 1,000 matters handled since inception, the team provides partner-direct involvement on every engagement and is experienced in co-ordinating with foreign counsel in multi-jurisdictional recovery mandates.

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/

In advising Korean-connected creditors on Russian asset recovery since 2022, one doctrinal pressure point has emerged with notable consistency: the moment a respondent identifies a Korean claimant as operating within US dollar clearing infrastructure, OFAC sanctions arguments enter the Russian courtroom. In a recent arbitrazh matter that crystallised this pattern, a corporate respondent sought to defeat a pledge enforcement claim partly on the basis that performance of the underlying obligation would expose the claimant to potential US regulatory liability. The Russian court's treatment of that argument offers practical guidance for foreign firms advising creditors from EAEU-adjacent jurisdictions — including Korea — who are building or refining their Russian asset recovery strategy.

The underlying dispute arose from a secured financing arrangement in which a Korean-affiliated corporate entity held a pledge over Russian commercial assets — a form of security that, under Russian civil and commercial law, is recognised and enforceable through the arbitrazh court system. When the debtor defaulted, the Korean-affiliated creditor initiated enforcement proceedings before the competent Russian arbitrazh court, seeking judicial sale or direct transfer of the pledged asset.

The respondent's defence combined conventional procedural objections with a more novel argument: that the creditor's Korean corporate parent maintained banking relationships with US-dollar correspondent banks, and that any realisation of the pledge would therefore involve transaction flows that could trigger OFAC jurisdiction. The respondent characterised this as a supervening legal impossibility, effectively inviting the Russian court to treat OFAC sanctions as a factor bearing on the enforceability of the Russian-law security interest.

This framing — importing US regulatory analysis into a Russian civil enforcement proceeding — was not entirely without precedent. Russian courts had previously encountered sanctions-based objections in a range of commercial matters. However, the application to a Korean claimant, rather than a claimant from a jurisdiction directly listed under the relevant US sanctions framework, raised a more nuanced question about third-country exposure and the reach of OFAC's 50 Per Cent Rule to creditor-side structures.

The arbitrazh court declined to engage with the OFAC argument as a substantive defence to enforcement. In its reasoning, the court applied a consistent principle drawn from Russian private international law: the applicable law governing the pledge and its enforcement is Russian law, and a foreign regulatory regime does not extinguish or suspend a right that is validly constituted and enforceable under that Russian law. The court found that the respondent had not demonstrated that Russian law itself rendered the obligation unenforceable, nor that any competent Russian authority had issued a directive restricting the transaction. The OFAC argument, being grounded in US federal regulation, was treated as an external constraint for the claimant to manage — not a legal defect in the claimant's Russian-law entitlement.

The court also addressed the structure of the Korean-affiliated creditor with some precision. It observed that the identity of the beneficial owner's jurisdiction of incorporation, and the banking practices of the corporate group, were matters beyond the scope of Russian arbitrazh jurisdiction to evaluate for US regulatory compliance purposes. In practical terms, the court applied the principle of regulatory competence separation: a Russian commercial court adjudicates Russian-law rights; the question of whether exercising those rights triggers a foreign regulatory consequence is a matter for the rights-holder and its advisers, not a ground for the Russian court to decline enforcement.

Enforcement of the pledge was ordered. The court applied the standard Russian procedural mechanism for pledge realisation — judicial sale through a licensed auction process — and did not modify the enforcement route to accommodate any OFAC-adjacent concern.

"What this ruling confirms, at a practical level, is that the Russian arbitrazh court will not act as a surrogate OFAC compliance assessor for either party. The creditor's Russian-law entitlement stands on its own ground." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign law firms advising Korean creditors on Russian enforcement proceedings, establishing local counsel early in the matter is the most reliable way to assess whether the debtor's OFAC-framed objections have any real procedural traction. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For Korean-affiliated creditors — including those whose structures route through jurisdictions with US dollar exposure — this ruling reinforces a significant point: the existence of a potential OFAC compliance issue on the creditor's side does not, under the prevailing approach of Russian arbitrazh courts, translate into a defence available to the Russian respondent. The two legal problems operate in separate regulatory domains. A respondent that raises OFAC-framed arguments is, in effect, borrowing a foreign regulatory concern and asking a Russian court to treat it as a Russian-law consequence. Russian courts have consistently declined that invitation.

This does not mean Korean creditors can disregard OFAC analysis altogether. The question of whether realising a Russian pledge or enforcing a Russian judgment creates OFAC exposure for the Korean creditor or its banking counterparties is a genuine one — particularly where the underlying asset involves sectors or counterparties that may independently attract US restrictions, or where the creditor's own corporate group maintains US-nexus activities. That analysis belongs in the creditor's pre-enforcement strategy, handled by counsel with both Russian enforcement expertise and familiarity with US sanctions architecture. It does not belong in the Russian courtroom as a respondent's weapon.

Foreign law firms advising on Russian asset recovery for Korean clients should also note the EAEU and CIS dimensions of this analysis. Korea's trade and financial relationships with EAEU member states introduce a layered jurisdictional picture: assets may be held through Russian entities with cross-border exposure to Belarus, Kazakhstan, or Armenia, and the enforcement chain may cross multiple jurisdictions before reaching a realisable outcome. The firm's Asset Tracing & Recovery practice regularly advises on cross-border enforcement chains of this nature — including matters where Korean and other Asian creditors hold security over assets located in Russia and connected EAEU jurisdictions. Related analysis on the Federal Tax Service's guidance on sanctions-adjacent transactions is available at Federal Tax Service issues guidance on OFAC-related compliance in Russian transactions, and the broader strategic framework for Korean creditors is addressed in OFAC sanctions intersection with Russian asset recovery strategy: a practitioner's briefing.

Practitioners coordinating Korean-creditor mandates with Russian enforcement proceedings may also find it useful to review the firm's matters record for illustrative outcomes in comparable cross-border recovery contexts.

• Federal Tax Service issues guidance on OFAC-related compliance in Russian transactions
• OFAC sanctions intersection with Russian asset recovery strategy: a practitioner's briefing
• Asset Tracing & Recovery — practice overview

Q: What does this ruling change about how Russian arbitrazh courts treat OFAC-based defences in enforcement proceedings?

A: The ruling reinforces the principle, which Russian arbitrazh courts have applied in a range of enforcement contexts, that foreign sanctions regimes do not constitute a ground for declining to enforce a validly constituted Russian-law right. A respondent seeking to defeat a pledge enforcement claim by reference to the claimant's potential OFAC exposure will typically find that the Russian court treats this as a matter external to Russian-law adjudication. The court does not assess whether the claimant's transaction would trigger US regulatory consequences; it assesses whether the claimant's Russian-law entitlement is established. In practice, this means that a Korean-affiliated creditor holding Russian security is unlikely to lose enforcement proceedings in a Russian arbitrazh court purely because its banking structure has US dollar exposure.

Q: What should foreign companies and their advisers do in light of this decision?

A: Foreign law firms advising Korean or other Asian creditors with Russian asset recovery claims should treat the OFAC analysis and the Russian enforcement strategy as two distinct but parallel workstreams. The Russian enforcement workstream should be initiated without delay, since arbitrazh procedural timelines and creditor-priority mechanics operate independently of the creditor's own OFAC position. The OFAC workstream — assessing whether realisation of Russian assets creates US regulatory exposure for the creditor or its group — should be conducted with US sanctions counsel, ideally before enforcement is pursued. Firms that handle only one of these workstreams should ensure the other is covered by co-counsel. Vetrov & Partners manages the Russian enforcement side and routinely coordinates with external sanctions counsel on the cross-border framing.

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 — including Korean, European, and Asian institutional and corporate creditors — on the enforcement of Russian-law security interests, cross-border asset tracing, and insolvency-adjacent recovery in the arbitrazh court system. The team combines deep procedural knowledge of the Russian enforcement framework with direct partner involvement at every stage.

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

If you are advising a Korean or Asian creditor on Russian asset recovery and need a confirmed Russian counsel relationship — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

The intersection of digital asset enforcement and state-adjacent counterparties in Russia is producing some of the most technically demanding instructed matters in cross-border recovery work today. In a series of decisions handed down by Russian arbitrazh courts over the past two years, judicial panels have had to determine whether cryptocurrency holdings and other digital financial assets constitute traceable and attachable property when the respondent is a company with state participation — a legal question that Russian procedural law was not designed to answer directly. The developing judicial practice is instructive both for what it resolves and for what it deliberately leaves open.

Russian law formally recognised digital financial assets and digital currency as distinct categories of property in 2020, and subsequent legislative developments extended this framework to address their treatment in civil enforcement and insolvency proceedings. For creditors, the relevant question has always been practical: can a court order the identification, freezing, and recovery of cryptocurrency holdings, and does the answer change when the counterparty is a state-owned or state-controlled entity?

The matters that have reached the arbitrazh courts in recent years have arisen primarily in the context of creditor claims against companies in which federal or regional government bodies hold a controlling or significant interest. These entities occupy an unusual procedural position. They are subject to ordinary civil jurisdiction, unlike sovereign bodies, yet their structural links to the state complicate enforcement at every stage — from obtaining disclosure orders to executing against assets that may be held through layered legal structures or transferred to affiliated bodies before a judgment is registered.

The legal question that emerged across this line of decisions was whether digital assets held by or traceable to such entities could be made subject to provisional measures and final enforcement orders in the same manner as conventional property. The short answer, as the courts have now indicated, is that they can — subject to significant procedural conditions.

Advising a foreign creditor with a claim against a Russian state-related counterparty? Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

In a matter decided by a first-instance arbitrazh court and subsequently affirmed on appeal, the court was asked to impose interim relief freezing digital currency balances traceable to a respondent company with a government shareholding exceeding fifty per cent. The claimant, a foreign trade creditor, relied on Russian civil procedure rules permitting the court to apply provisional measures over any property of the respondent, without limitation as to asset type. The respondent argued that digital currency did not constitute "property" in the sense contemplated by the procedural rules, and that even if it did, the state participation in the company created structural obstacles to enforcement.

The court rejected both arguments. On the property question, the panel held that digital currency — as defined under Russian legislation on digital financial assets — falls within the category of assets over which interim measures may be granted, provided that the claimant identifies the relevant wallet address or exchange account with sufficient particularity. On the state-participation point, the court confirmed that commercial entities with state shareholdings do not enjoy enforcement immunity under Russian procedural law and are subject to the same attachment and execution rules as privately held companies.

What is notable — and what experienced creditor counsel will recognise as the more significant development — is the court's treatment of the disclosure question. The panel indicated that a respondent company's refusal to disclose the location of its digital asset holdings, when a creditor has produced prima facie evidence of their existence, may be treated as an adverse inference in enforcement proceedings. This represents a meaningful shift in the evidentiary posture available to creditors pursuing digital assets held through opaque corporate structures.

"The court's willingness to treat non-disclosure of digital asset holdings as an adverse inference marks a practical turning point for creditors instructing Russian enforcement counsel against state-adjacent counterparties." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

For foreign law firms instructing Russian counsel in creditor-side recovery matters, this line of decisions has three immediate implications.

First, the threshold for interim measures over digital assets has been clarified. A claimant need not prove with certainty that the respondent holds digital assets — it must produce credible evidence of that likelihood and identify the relevant infrastructure (exchange account, wallet, or custodial arrangement) with reasonable specificity. This is a demanding but workable standard, and one that rewards early investigative work before the claim is formally lodged.

Second, the state-participation defence has been definitively closed at the commercial entity level. Foreign creditors and their counsel should not assume that a respondent's government-ownership structure provides any procedural immunity under Russian law. The relevant distinction is between commercial entities with state shareholdings — which are fully subject to civil enforcement — and state bodies themselves, which are not. Careful counterparty analysis at the outset of any recovery mandate remains essential.

Third, the adverse-inference approach to digital asset disclosure changes the dynamic of pre-trial correspondence and formal disclosure requests. Building a documented record of unanswered or refused disclosure requests may now serve a strategic function that goes beyond the usual evidential purposes. Counsel coordinating cross-border tracing work should factor this into the case management strategy from an early stage.

The firm has acted in creditor-side matters involving digital asset tracing against Russian counterparties, including instances where the respondent was a company with government participation. In each case, the procedural complexity of establishing the asset identification threshold was the principal practical obstacle — not the legal framework, which has become more creditor-friendly with each successive decision.

For firms advising clients with live Russian enforcement mandates where the counterparty has state-related characteristics, confirming the counterparty's exact legal status — commercial entity versus state body — is the first step that shapes every subsequent procedural choice.

Discuss a cross-border digital asset tracing mandate with our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Russian Supreme Court Clarification on Digital Asset Tracing: What Changed
• Navigating Digital Asset and Cryptocurrency Tracing in Russia: A Practical Guide
• Asset Tracing and Recovery in Russia: Practice Overview

Q: What does this ruling change for creditors pursuing digital asset claims in Russia?

A: The decisions confirm two points that were previously uncertain in Russian judicial practice. First, digital currency and digital financial assets are property subject to interim measures and final enforcement orders under Russian civil procedure — the courts have declined to treat them as a category apart. Second, commercial entities with state shareholdings do not receive enforcement immunity by virtue of that structure. The practical change is most significant in the area of disclosure: courts are now prepared to treat a respondent's systematic non-disclosure of digital asset holdings as an adverse inference, which gives creditors a procedural lever that did not previously exist in this context.

Q: What should foreign companies — or their counsel — do in light of this decision?

A: Firms instructing Russian counsel in creditor-side recovery matters against state-related entities should review two things immediately. First, whether the counterparty is a commercial entity with state participation (fully subject to civil enforcement) or an actual state body (which enjoys different procedural treatment). This distinction is frequently overlooked by foreign counsel unfamiliar with the Russian corporate landscape. Second, whether any pre-claim investigative work has been done to identify digital asset holdings — exchange accounts, custodial arrangements, or on-chain wallet activity attributable to the respondent. The courts now require reasonable particularity in identifying the relevant infrastructure, and that preparation is most effective before the claim is lodged and the respondent has notice of the proceedings.

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

The firm's asset tracing and recovery practice advises foreign creditors and foreign law firms on the identification, freezing, and enforcement of Russian assets, including digital financial assets and cryptocurrency holdings. The practice combines investigative support, procedural expertise before the Russian arbitrazh courts, and partner-direct involvement on every mandate. With over 1,000 matters handled since inception, the team is well-positioned to coordinate cross-border tracing work alongside foreign counsel.

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/

Russian corporate registry searches for asset tracing follow four principal procedural steps under Russian law: identification of the legal entity in the Unified State Register of Legal Entities (EGRUL), extraction of ownership and shareholding data, cross-referencing with affiliated entities, and validation against the Rosreestr real property register and the Federal Bailiff Service enforcement database. Each step produces documents admissible in Russian arbitrazh court proceedings and useful for foreign enforcement purposes.

The EGRUL, maintained by the Federal Tax Service, is the starting point for any corporate registry search in Russia. A search produces a current extract confirming the entity's registered address, directors, authorised capital, and shareholder composition. Under Russian civil procedure, EGRUL extracts carry evidentiary weight. The subsequent step — mapping corporate affiliates and beneficial ownership structures through registry cross-references — is typically conducted using the same registry infrastructure, supplemented by data from the Federal Antimonopoly Service and, where available, Rosreestr title records for immovable property held directly or through subsidiaries.

In practice, foreign creditors undertaking corporate registry searches in Russia frequently underestimate the timeline: a full multi-entity search, including affiliated-company mapping and Rosreestr cross-referencing, typically requires four to eight weeks depending on the complexity of the ownership chain. Creditors who delay initiating this process risk that asset disposals or corporate restructurings completed before a freezing order is sought will limit the recoverable pool — under Russian insolvency legislation, preferential transfer challenges have defined look-back windows that a well-timed asset search can protect against.

Foreign creditors and their advisers should instruct Russian-qualified counsel early in the process. Registry access for foreign entities is not direct in all cases; requests are channelled through a licensed representative, and document translation and legalisation requirements add procedural steps for cross-border use. Our detailed guidance on this practice is available at Russian Corporate Registry Searches for Asset Tracing and A Practical Guide to Russian Corporate Registry Searches. For the broader framework, see our Asset Tracing & Recovery practice page.

To discuss a corporate registry search in Russia or to instruct us on an asset tracing matter — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Rosreestr — the Federal Service for State Registration, Cadastre and Cartography — maintains Russia's unified state register of rights to immovable property. Under Russian civil and land legislation, ownership interests, encumbrances, mortgages, and restrictions on real property are subject to mandatory registration. As a general rule, these rights do not take legal effect until that registration is completed. The register is accessible to third parties, including foreign creditors seeking to identify or trace Russian property assets, which makes it a primary starting point in any asset-tracing exercise.

Russian law permits any person to submit an information request to Rosreestr and obtain an extract disclosing the registered owner of a specific parcel or building. The extract also shows any encumbrances, arrests, or prohibitions on disposal recorded against that object. Extracts are available through the Rosreestr online portal and through the Multifunctional Centre network. Certain categories of expanded information — including the broader transaction history of an object — are available to owners, authorised state bodies, and, in the context of enforcement or insolvency proceedings, to court-appointed officials. A foreign creditor acting through Russian-qualified counsel can obtain standard ownership extracts directly; access to deeper historical data typically requires engagement of the judicial or insolvency process.

For a foreign creditor pursuing enforcement against a Russian debtor, Rosreestr data is significant in two practical respects. First, it confirms whether real property assets exist and in whose name they are registered — a threshold question before any enforcement application to a Russian court can be mounted. Second, registered arrests and prohibitions visible in the register reveal whether competing creditors have already secured priority over specific assets. Creditors who delay initiating enforcement proceedings risk losing that priority to subsequently registered arrest orders — a consequence that can be difficult to reverse once insolvency proceedings are filed against the debtor.

To deploy Rosreestr data effectively within an enforcement strategy, foreign creditors are advised to instruct Russian-qualified counsel familiar with the Asset Tracing & Recovery process and the procedural steps for converting register information into actionable enforcement measures. The firm's approach to such mandates is set out in further detail in the article Rosreestr property register as an investigative tool in Russia.

To discuss enforcement strategy and Rosreestr-based asset tracing — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on identifying, tracing, and enforcing against Russian property assets, including through Rosreestr register analysis and judicial arrest applications. 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/

Elizaveta Razina leads the firm's intellectual property and asset protection practice, representing foreign interests in enforcement proceedings before Russian state courts and the IP Court. She advises on anti-counterfeiting strategy, parallel import controls, and asset-tracing exercises for foreign creditors and rights holders.

Yes — a foreign company that is a creditor or claimant in Russian proceedings can participate in tracing bank accounts and financial flows in Russia, principally through court-ordered disclosure mechanisms available under the arbitrazh procedure and general civil procedure rules.

Russian law does not grant foreign creditors a direct right to subpoena banks or demand financial information unilaterally. Disclosure is court-mediated: a foreign creditor who has initiated, or is a party to, proceedings before a Russian arbitrazh court or a court of general jurisdiction may apply for a judicial inquiry directed at credit institutions, the Federal Tax Service, or the Federal Bailiff Service. Those bodies are obliged to respond to the court's inquiry within the established procedural timeframe. The court then furnishes the information to the requesting party. This mechanism extends to tracing bank accounts, identifying account balances, and mapping financial flows between related entities. Foreign claimants are treated on the same procedural footing as Russian creditors for these purposes.

In practice, the scope and speed of disclosure depend on the stage of proceedings. The most effective tracing typically occurs once enforcement proceedings have commenced or during bankruptcy proceedings against the debtor, where the insolvency administrator also holds independent disclosure powers. Creditors who delay initiating proceedings risk the debtor dissipating assets or restructuring financial flows in ways that materially narrow the scope of what can be traced before a court order is issued. Interim measures — including account freezes — may be sought alongside a disclosure application to preserve the position.

For cross-border matters, the firm also coordinates with counsel in other jurisdictions where parallel asset-tracing steps may be available, including disclosure proceedings under English, Dutch, or German procedural law.

For further context on Russian tracing procedure, see our asset tracing and recovery practice page, our analysis of the Russian Supreme Court clarification on tracing, and our practitioner briefing on navigating bank account and financial flow tracing.

If you are a foreign creditor seeking to trace bank accounts or financial flows in Russia — 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 asset tracing and protection strategy across practice areas.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on court-assisted disclosure, account freezes, and enforcement against Russian-domiciled debtors. 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.

Unwinding a shell company structure with Russian elements typically takes between one and three years, though complex multi-tier arrangements can run longer. The precise timeline depends on the number of legal entities involved, the nature and location of the underlying assets, whether Russian insolvency proceedings are active or anticipated, and whether the structure spans multiple jurisdictions beyond Russia. There is no single procedural route: creditors pursuing distressed assets under Russian law must work across corporate dissolution, enforcement, and — where fraud is alleged — asset tracing mechanisms that each carry their own procedural timelines.

Under Russian law, the unwinding process engages several distinct legal regimes. At the corporate level, liquidation of a Russian entity through a solvent voluntary dissolution proceeds in a matter of months under standard conditions, though regulatory clearances from the Federal Tax Service and mandatory creditor notification periods extend the minimum timeframe to roughly six months. Where assets have been transferred through the shell structure — a common feature of distressed situations — the relevant tools are subsidiary liability claims, voidance of suspect transactions, and, where insolvency proceedings are in progress, challenges within the statutory look-back windows applicable to preferential and undervalue transfers. Each of these mechanisms involves separate court proceedings in the Russian arbitrazh courts.

For foreign creditors enforcing against Russian-linked shell structures, the practical risk of delay is acute. An asset that is not frozen or registered against at the outset of proceedings may be dissipated through further transfers before enforcement completes. Under Russian civil procedure, interim asset preservation measures are available but not automatic: they must be applied for promptly and on proper evidentiary grounds. Creditors who allow the structure to continue operating while investigating their options risk losing the practical benefit of their legal position. The Asset Tracing & Recovery practice note on shell structure unwinding in Russian proceedings sets out the procedural sequence in detail.

The recommended first step for a foreign creditor facing a Russian shell structure is to map the corporate layers, identify asset-holding entities within Russia, and assess whether any insolvency petition has been filed or is imminent. That assessment determines which procedural tools are available and, critically, whether any limitation periods or look-back windows are running. Early instruction of Russian counsel is material: the options available at the start of proceedings are materially broader than those available once the structure begins to unwind under court supervision.

If you are a foreign creditor dealing with a Russian shell structure — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Cyprus-Russia corporate structures that relied on a Cypriot holding entity above a Russian operating subsidiary now face a substantially more demanding documentary environment than existed before 2022. Following the suspension of the double taxation treaty between Russia and Cyprus in 2023 and the tightening of Russia's de-offshorisation rules, foreign creditors holding interests through such structures — or seeking to enforce against them — must account for a significantly expanded disclosure and verification regime.

Under Russia's controlled foreign company legislation and beneficial ownership disclosure requirements, the Russian operating entity in a Cyprus-Russia chain is typically required to maintain and produce current documentation confirming the ultimate beneficial owner, the corporate chain up to the natural person level, and the economic substance of the Cypriot holding entity. In practice, Russian tax authorities and courts have increasingly required notarised and apostilled copies of Cypriot corporate documents — articles of association, certificates of good standing, shareholder registers, and director resolutions — translated into Russian by a certified translator.

For foreign creditors seeking to trace or enforce against assets held through such structures, the evidentiary standard is directly affected. A Russian arbitrazh court will generally require the claimant to establish that the corporate chain is validly constituted and that the entity through which assets are held retains legal personality in Cyprus. Since the DTT suspension removed automatic treaty protections, demonstrating the independence and substance of the Cypriot entity has become a live procedural question rather than a formality.

Currency control filings, where cross-border transactions between the Cypriot entity and its Russian subsidiary remain active, add a further documentation layer: Russian currency control authorities typically require account statements, transaction passports, and written justification for any ongoing intercompany payments.

If you are tracing assets or enforcing a claim against a Cyprus-Russia corporate structure, early-stage documentary verification is essential to avoid procedural objections that can delay or derail Russian court proceedings. Our Asset Tracing & Recovery practice advises on precisely this documentary groundwork. For further context on how Russian courts analyse these structures, see our analysis at How Russian courts approach Cyprus-Russia corporate chains.

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.

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.

Under Russian law, standing to pursue enforcement against UAE real estate held by a Russian national typically belongs to three categories of party: a judgment creditor holding an enforceable Russian court decision, an appointed insolvency administrator acting on behalf of the creditor body in Russian bankruptcy proceedings, or a secured creditor whose pledge over the asset was properly registered before the debtor's financial distress. The answer turns principally on the legal basis on which the creditor proceeds and the procedural status of Russian proceedings at the time enforcement is sought.

Russian civil procedure and insolvency legislation establish the gateway. A judgment creditor who has obtained an enforceable award from a Russian arbitrazh court or general jurisdiction court acquires the right to trace the debtor's assets, including those situated abroad. Enforcement against foreign-located assets is then subject to the procedural rules of the jurisdiction in which they are held. Where Russian bankruptcy proceedings have been opened, the insolvency administrator assumes standing on behalf of all creditors and individual creditor action is generally superseded. Creditors nonetheless retain specific rights – to challenge transactions and to seek recognition of Russian insolvency proceedings in foreign courts. A pledgee retains independent standing to enforce against the specific pledged asset, provided the pledge was registered in the relevant registry and remains legally effective.

In practice, UAE-situated real estate introduces a second jurisdictional layer. A Russian court decision or insolvency order is not self-executing in the UAE. Separate recognition proceedings before UAE courts – or, where applicable, the DIFC or ADGM courts – are required before local enforcement can proceed. This is a matter governed by UAE law, not Russian law. The firm's Asset Tracing & Recovery practice advises on the Russian-law standing analysis and the construction of cross-border enforcement strategy; coordination with UAE-qualified counsel is arranged where instructed.

If you are assessing whether you hold standing under Russian law to initiate enforcement against UAE-situated assets, an initial review of the basis of your claim and the debtor's current procedural status in Russia is the practical starting point.

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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Coordinating enforcement across Russia and foreign jurisdictions typically involves four distinct cost layers: Russian counsel and court fees, foreign counsel fees in the recognition or parallel enforcement jurisdiction, document legalisation and translation, and asset-tracing disbursements. The total varies considerably depending on asset value, the number of jurisdictions involved, and whether the foreign jurisdiction is a CIS or EAEU treaty partner — treaty-based enforcement routes can materially reduce procedural overhead compared with non-treaty routes.

Russian court fees for property claims before the arbitrazh courts are proportional to the amount in dispute, subject to a statutory ceiling. Asset-tracing work — registry searches across Rosreestr, the EGRUL, the National Pledge Registry, and sector-specific databases — carries its own disbursement budget, which expands when tracing extends across multiple legal entities or asset classes. The Federal Bailiff Service levies an enforcement charge on recovered amounts once a judgment enters the execution phase; creditors should account for this in their recovery projections.

On the foreign side, costs depend on the jurisdiction and the procedural route. Where Russia is a party to a bilateral or multilateral treaty — as it is under the CIS framework for member states — recognition proceedings tend to be shorter and less costly than full de novo enforcement proceedings. Outside that framework, foreign counsel fees for recognition actions can equal or exceed the Russian-side legal spend, particularly in common law jurisdictions where adversarial recognition hearings are more resource-intensive.

Translation and legalisation costs are often underestimated. Documents produced in Russian proceedings must be certified, translated, and in many cases apostilled before they are usable in a foreign court. For complex matters involving multiple tranches of documentary evidence, this line item can be material.

For a structured cost estimate tailored to your recovery scenario, including Russian asset-tracing scope and cross-border procedural route, 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

Further reading: Asset Tracing & Recovery — practice overview | Court practice on coordinating enforcement | Key risk points in coordinating enforcement

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.

Missing a compliance deadline in a worldwide freezing order affecting Russian-situated assets has consequences at two distinct levels: the issuing court's jurisdiction, and the separate question of whether those Russian-situated assets remain effectively restrained at all. The answers are not the same, and foreign creditors in Russia enforcement situations frequently conflate them.

At the level of the issuing court – typically an English, BVI, or Cayman Islands court – a missed deadline triggers that court's contempt jurisdiction. The respondent or a third party who has knowingly assisted in breach may face sanctions including fines, asset-seizure orders, or, in personal cases, committal. Whether the creditor loses the benefit of the order depends on what the deadline governed: a return-date failure may allow the respondent to apply for discharge; a disclosure deadline failure leaves the asset picture incomplete and may weaken subsequent enforcement steps.

For Russian-situated assets specifically, a worldwide freezing order does not directly bind Russian courts or Russian-domiciled asset-holders. Russian civil procedure does not recognise the in personam character of a common-law freezing injunction as automatically enforceable on Russian territory. A creditor seeking to restrain assets within Russia must, as a general rule, pursue separate interim relief through Russian court proceedings – an application for provisional measures (обеспечительные меры) – anchored to substantive Russian or recognised foreign proceedings. If the underlying foreign order lapses or is discharged because a deadline was missed, the factual basis for any parallel Russian application is significantly weakened, and a Russian court will examine the current status of the foreign restraint as part of its assessment.

The practical consequence for a foreign creditor is that a missed WFO deadline in the issuing jurisdiction can unravel the entire enforcement architecture: the foreign restraint lapses, the parallel Russian application loses its evidentiary foundation, and an informed respondent will move quickly to dissipate or transfer Russian-situated assets in the window that opens. Russian courts do not grant interim relief retroactively.

If a deadline has been missed or is approaching, the priority is to seek an urgent extension or renewal in the issuing court before the Russian procedural position deteriorates. Simultaneously, counsel should assess whether an independent Russian provisional-measures application can be filed on the basis of the substantive claim alone, without reliance on the foreign order.

For a detailed account of the procedural framework, see Worldwide Freezing Orders and Russian-Situated Assets and A Practical Guide to Worldwide Freezing Orders. The firm's Asset Tracing & Recovery practice page sets out how we coordinate across jurisdictions in these situations.

If a WFO deadline has been missed or is at risk, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

— Elizaveta Razina Senior Lawyer, Practice Lead – Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

Elizaveta Razina leads the firm's intellectual property and asset tracing practice, representing foreign creditors and asset holders in proceedings before Russian state courts. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Russian civil procedure does not, as a general rule, impose mandatory legal representation on foreign creditors pursuing asset recovery in Russian courts. A foreign legal entity may act through an authorised representative under a power of attorney. Where an asset recovery strategy intersects with the OFAC sanctions framework — because the debtor, its assets, or the transaction chain involves US-designated parties — the representation question shifts from Russian procedural choice to a matter of US regulatory obligation, which lies outside Russian law entirely.

Under Russian arbitrazh procedure, parties may participate directly or through a representative; the law does not compel a party to retain an advokat or any particular class of legal professional. The firm's Asset Tracing & Recovery practice (/practices/asset-tracing-recovery/) regularly acts for foreign creditors navigating this dual framework. Where OFAC blocking provisions or licence conditions apply, substantive activity — including instructing counsel, transferring enforcement proceeds, or settling a claim — may require a specific OFAC licence before it can lawfully proceed. That analysis is a matter of US law, not Russian law. Vetrov & Partners is a Russian-qualified firm; for the US-law dimension, we coordinate with trusted US-qualified advisers.

In practice, foreign creditors operating under active OFAC constraints rarely proceed without Russian legal counsel, not because Russian law requires it, but because coordinating enforcement steps — interim measures, asset freezes, creditor meetings in insolvency proceedings — through qualified counsel substantially reduces the risk of inadvertent procedural missteps and licence-compliance gaps. The intersection is examined in the firm's analysis of the OFAC sanctions overlap with Russian asset recovery strategy (/insights/atr-pb-009-ofac-sanctions-intersection-with-russian-asse/).

Creditors assessing whether their specific recovery strategy engages both Russian procedural requirements and OFAC obligations benefit from early dual-track analysis: Russian enforcement counsel confirming the procedural position, and US-qualified advisers confirming the licence position. Starting that analysis before enforcement steps are taken preserves the widest range of options.

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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Yes — decisions issued in digital asset and cryptocurrency tracing proceedings in Russia are subject to appeal under the standard hierarchy of Russian civil and arbitrazh procedure, though the grounds and timelines are strictly defined and a foreign creditor who delays risks losing the right to challenge entirely.

Under Russian law, courts may grant tracing orders, impose interim freezes, or issue enforcement determinations affecting digital financial assets and cryptocurrency held by a debtor. These decisions are procedural orders or substantive judgments depending on their form, and each category carries its own appellate route. Interim measures — including asset freezes — may be challenged by way of a separate application to the court that issued them, or appealed to the appellate instance within a short timeframe that, in practice, commonly runs to fifteen days from the date of service. Substantive tracing determinations follow the standard appellate ladder: appeal instance, cassation, and, in appropriate cases, supervisory review. At each stage, the grounds for challenge are formal: procedural irregularity, misapplication of substantive law, or a finding that the court lacked jurisdiction over the asset class in question. The developing nature of Russian digital asset regulation means that jurisdiction and asset classification arguments have, in a number of recent proceedings, succeeded at the appellate stage — though outcomes vary by circuit and the legal framework continues to evolve.

For a foreign creditor holding a tracing order against a Russian counterparty, the practical priority is twofold: monitoring whether the debtor has filed an appeal that might suspend enforcement, and assessing whether the order itself should be appealed on grounds of under-inclusion if assets were excluded from its scope.

The firm's Asset Tracing & Recovery practice advises foreign creditors on enforcement proceedings involving digital assets in Russian courts, including appellate strategy. Further background is available in Navigating Digital Asset and Cryptocurrency Tracing in Russian Proceedings.

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, parallel import controls, and asset tracing matters involving digital assets and intangible property.

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.

Under Russian anti-money laundering and counter-financing of terrorism legislation, legal entities incorporated in Russia are subject to a multi-step beneficial ownership disclosure regime. For a foreign creditor pursuing asset recovery or conducting enforcement due diligence, understanding what Russian counterparties are obliged to disclose — and to whom — can materially affect both the tracing strategy and the documentary basis for any claim.

The procedural obligations fall into four principal stages. First, every Russian legal entity must identify its beneficial owners: individuals who directly or indirectly hold a stake of twenty-five per cent or more, or who otherwise exercise effective control over the entity. This identification step is not a one-off exercise — the entity is required to take active steps to establish and verify beneficial ownership on a continuing basis. Second, the entity must maintain an internal register of beneficial owner information, updated within three business days of any change in ownership or control. Third, the entity is obliged to disclose beneficial ownership information to the authorised financial monitoring body upon request; non-compliance carries administrative and, in certain circumstances, criminal liability. Fourth, under Russian tax legislation as developed through successive amendments, legal entities must report beneficial ownership details to the tax authorities, typically on an annual basis.

For foreign creditors, the practical significance lies in access. These disclosed records — held by Rosfinmonitoring, the Federal Tax Service, and in certain cases the legal entity itself — may be accessible through disclosure orders, litigation support proceedings, or via local counsel's information channels in the course of enforcement. Where a Russian debtor has layered offshore structures, the beneficial ownership disclosure framework provides a statutory paper trail that courts and insolvency administrators can compel production of.

Beneficial ownership records are among the earliest documentary sources the firm examines in cross-border asset tracing and distressed asset recovery matters. For a fuller treatment of the legislative framework, see Beneficial Ownership Disclosure Obligations Under Russian Law and the firm's Asset Tracing & Recovery practice page.

If you are a foreign creditor seeking to identify or locate Russian assets held through layered structures, the documentation trail created by beneficial ownership disclosure obligations is a material starting point. 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 and asset protection practices, representing foreign creditors and asset holders in proceedings before Russian state courts. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Russian law provides creditors with substantive tools to identify, challenge, and unwind nominee arrangements used to conceal assets from enforcement — though the strength of any challenge depends on when it is brought, which forum applies, and how the arrangement was documented. For foreign creditors with Russian asset-recovery interests, understanding how these mechanisms operate in practice is a prerequisite to any enforcement strategy under Asset Tracing & Recovery.

Under Russian civil legislation, transactions that are simulated — that is, concluded to create the appearance of a legal relationship without the parties intending to be bound by it — are void. Courts treat nominee arrangements of this character as feigned transactions and may disregard them, effectively restoring the concealed asset to the enforcement pool. Where an arrangement is established as a cover for a different transaction, courts may reclassify it and apply the rules governing the underlying relationship instead. These are stable doctrines: Russian courts across most circuits have applied them consistently in asset-tracing litigation, although the evidentiary standard required to establish sham intent varies in practice and is often the central litigation contest.

In insolvency proceedings, the unwinding tools are, as a general rule, broader. The insolvency legislation permits a liquidator or creditor to challenge transactions that transferred value out of the debtor's estate within defined look-back periods, including arrangements that nominally transferred ownership to a related party at an undervalue or without genuine consideration. The courts have generally held that the burden of demonstrating commercial rationale shifts, in certain circumstances, to the party who received the transferred asset.

For a foreign creditor seeking recovery from a Russian debtor, nominee arrangement risks are a live concern from the moment debt becomes distressed. Delay in tracing and challenging disposals can extinguish the recovery window. Creditors who have not yet mapped the debtor's asset position — including transfers to nominees — should do so before insolvency proceedings are formally opened, since the procedural options available after filing differ materially from those available before. Our analysis of how Russian courts approach nominee arrangements in contested asset-recovery litigation is set out in How Russian Courts Approach Nominee Arrangements.

For foreign creditors assessing recovery exposure against a Russian counterparty — 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, within the firm's Asset Tracing & Recovery work, on asset-identification and recovery questions that intersect with IP and ownership structures.

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.

Yes. A foreign company can participate in fraudulent transfer analysis under Russian civil law. Russian law permits creditors — including foreign legal entities — to challenge transactions that deprive them of recovery from a debtor, subject to applicable standing requirements and limitation periods.

Two frameworks apply. Under general Russian civil law, transactions concluded in bad faith or with the intent to harm creditors may be recognised as voidable at the instance of an affected creditor before a Russian arbitrazh court. Additionally, where a debtor is subject to Russian insolvency proceedings, Russian insolvency legislation provides a separate mechanism for challenging antecedent transactions. This covers disposals at an undervalue and preferential payments made to connected parties. Look-back periods typically range from six months to three years, depending on the nature of the transaction and the relationship between the parties. Foreign creditors who have been admitted as creditors in the insolvency generally have standing to bring or support these challenges.

For a foreign creditor pursuing recovery from a Russian debtor, fraudulent transfer analysis is often the most direct route to reversing pre-insolvency asset disposals. Courts have generally recognised that assets transferred to affiliated entities or at below-market value can be returned to the debtor's estate, improving the pool available to creditors. The analysis requires evidence of the transaction terms, the relationship between transferor and transferee, and the timing relative to the creditor's claim or the debtor's financial deterioration.

A foreign creditor seeking to challenge transactions should instruct experienced Russian counsel at the earliest stage. Limitation periods apply, and transactional records may become harder to obtain over time. The firm's Asset Tracing & Recovery practice [/practices/asset-tracing-recovery/] advises foreign creditors on fraudulent transfer analysis and antecedent transaction challenges before Russian courts. A related briefing on how these rules apply in practice is available at Foreign Creditors and Fraudulent Transfer Analysis [/insights/atr-pb-013-foreign-creditors-and-fraudulent-transfer-ana/].

To discuss a specific enforcement matter — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Russian courts must rule on interim relief applications in commercial proceedings without notifying the respondent, on the day of filing or the following business day. Most arbitrazh courts issue the order within one to two business days. For foreign creditors seeking to freeze Russian assets, that initial window is typically the only one available before a counterparty can move assets. The application is considered ex parte by design.

The ex parte rule applies under Russian civil procedure rules governing both arbitrazh courts and general jurisdiction courts. The court reviews the application on the papers alone, without a hearing. Courts retain discretion to extend consideration to five business days in complex matters, though this remains uncommon in straightforward freezing applications.

The critical risk for foreign creditors is not the court's response time but preparation time before filing. An application lacking properly translated documentation will typically be refused outright. The most common risk points in interim relief applications [/insights/atr-pb-014-key-risk-points-in-interim-relief-application/] are well-documented in practice. Creditors who delay instructing Russian counsel risk losing the enforcement window: a debtor alerted to proceedings can move assets within days.

Foreign creditors should instruct local counsel at the earliest stage — ideally before the claim is filed. Early instruction allows documentation to be prepared in parallel, removing the bottleneck that most commonly causes applications to fail. The firm's Asset Tracing & Recovery practice [/practices/asset-tracing-recovery/] advises on interim relief strategy in Russian proceedings.

For assistance with interim relief applications in Russian courts — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on enforcement strategy, interim relief applications, and cross-border asset recovery in Russian proceedings. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

— 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

To obtain a third-party disclosure order in Russian civil or arbitrazh proceedings, a creditor must file a written petition with the court specifying the third party's identity, describing the documents sought with reasonable precision, setting out the grounds of relevance to the live dispute, and demonstrating that voluntary production has been requested and refused or ignored. Without each of these elements, Russian courts will typically decline to compel disclosure.

Under Russian civil and arbitrazh procedure, courts have the power to compel a third party to produce documents held in its possession that are material to a pending claim. The application mechanism is a formal petition addressed to the presiding judge, submitted either before or during the substantive hearing. The petition must identify the third party by full legal name and address, describe the documents by type or category rather than by individual title — courts generally do not accept open-ended disclosure requests — and state why those documents are relevant and why they cannot be obtained by the requesting party through other means.

In practice, the strictness of the relevance and proportionality assessment varies across circuits. Courts in some districts require a supporting statement from the requesting party confirming that direct or informal requests for production were made and went unanswered; others treat this as implied by the filing of a formal petition. Where the third party is a financial institution — a bank, broker, or registry — additional procedural requirements may apply, and the court will often need to be satisfied that the information sought falls within the scope of disclosure permitted under applicable banking secrecy or data protection rules.

For foreign creditors tracing assets held through Russian corporate structures or seeking account information to support enforcement, the quality of the petition drafting is the critical variable. An imprecisely framed disclosure request is the most common reason courts reject such applications at first instance, creating delay in proceedings where the asset position may be deteriorating. Counsel familiar with the specific circuit and the presiding court's disclosure practice can materially improve the prospects of a first-instance grant.

For a detailed procedural analysis, see Third-Party Disclosure Orders in Russian Proceedings and the companion Practical Guide to Third-Party Disclosure Orders. The firm's Asset Tracing & Recovery practice page sets out the broader enforcement framework.

To discuss a third-party disclosure application or asset tracing matter in Russia — 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.

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.

Standing to initiate international letters rogatory directed at Russian authorities belongs, in the first instance, to the foreign court before which proceedings are pending — not to the creditor or claimant directly. A foreign trade creditor, distressed investor, or enforcement applicant must be a party to active proceedings in a competent foreign court before that court will, on the party's petition, issue a letter rogatory to the Russian side.

Under the mutual legal assistance frameworks applicable to Russia — the 1954 Hague Convention on Civil Procedure, the 1993 Minsk Convention on Legal Assistance (for CIS member states), and a network of bilateral judicial assistance treaties — the requesting entity is always the foreign court, not the creditor. The court acts on the creditor's petition, once the creditor has established that the assistance sought falls within the relevant treaty's scope and that the evidence or service requested is relevant and necessary to the claim.

For a foreign creditor with a Russian debtor, active proceedings before a competent court are a threshold precondition. Without them, no court exists to issue the letter, and no treaty basis exists for Russian authorities to act on the request. The Ministry of Justice of the Russian Federation acts as Central Authority under most applicable conventions, assessing incoming requests for treaty compliance before routing them to the competent Russian court or body.

Creditors from EAEU member states and CIS parties typically benefit from a more direct court-to-court channel under the Minsk and Chisinau frameworks. In practice, this shortens the transmission timeline materially compared with non-CIS treaty routes.

Where enforcement is pursued through arbitration rather than a state court, the position is more constrained. Russian procedural rules on international judicial assistance are directed at court-to-court requests. The standing of an arbitral tribunal to initiate letters rogatory through the Russian framework depends on the specific treaty in question and its scope as interpreted by Russian courts. Foreign creditors relying on arbitration to pursue Russian asset recovery should verify at the outset whether a parallel state court application to support evidence gathering is advisable.

Further context is available in our analysis of international letters rogatory directed at Russian courts and in the Rospatent international letters rogatory briefing at /insights/atr-lu-016-rospatent-issues-guidance-on-international-le/. For the broader procedural picture, see our Asset Tracing & Recovery practice overview.

For advice on initiating letters rogatory against Russian authorities, or on the procedural steps for enforcing a foreign claim 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 and asset recovery practice, representing foreign creditors and rights-holders in enforcement proceedings before Russian state courts. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including trade creditors and distressed investors — on enforcement against Russian debtors, international judicial assistance procedures, and cross-border asset recovery. 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.

Repatriating assets from Russia carries several distinct cost layers under Russian currency legislation, and foreign creditors who underestimate them frequently find that recovered amounts are materially lower than the judgment or award figure. The principal cost categories are conversion spreads, mandatory banking charges, regulatory compliance fees, and — where currency control obligations are breached — administrative penalties that can absorb a significant proportion of the transferred sum.

Russian currency legislation, administered by the Central Bank of Russia, governs all cross-border transfers of funds by residents and non-residents alike. For foreign creditors holding Russian-sourced assets, the framework imposes transaction reporting obligations, mandatory routing through authorised banks, and in certain categories of cross-border transfer, prior registration or notification requirements. Compliance with each of these steps generates direct costs: authorised-bank processing fees, currency conversion at rates set by the transacting institution, and professional fees for preparing the required documentation. Creditors operating through offshore structures should be aware that the rules applicable to transfers from Russian entities to non-resident accounts have been subject to successive regulatory amendments and must be verified against the current Central Bank position at the time of any transfer.

The practical cost exposure for a foreign creditor pursuing enforcement against a Russian-domiciled debtor typically includes: currency conversion losses on the transfer from roubles to the creditor's settlement currency; bank commission on outgoing cross-border transfers; legal and compliance costs for structuring the transfer in accordance with current currency control rules; and potential penalties for procedural breaches, which under Russian currency legislation can in some circumstances reach a material percentage of the unlawfully transferred or unreported amount. Timelines also carry an indirect cost: where a transfer requires advance authorisation or involves a staged regulatory process, the asset may remain exposed to further debtor action or insolvency risk during the intervening period.

Foreign creditors advising on recovery strategy for Russian assets should factor currency control compliance costs into their recovery model at the outset. For a fuller analysis of the procedural steps in Russian asset recovery, see Russian asset recovery: main procedural steps and the firm's overview at Asset Tracing & Recovery.

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 and advises on cross-border asset protection and recovery strategy. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Missing the enforcement deadline for an English court order in Russia is not a procedural technicality — it is the end of the road for Russian asset recovery. Under Russian civil and commercial procedural rules, a foreign creditor has a three-year window, running from the date the foreign judgment becomes enforceable, within which to file an application for recognition and enforcement before a Russian court. Once that window closes, the Russian court will refuse to accept the application on limitation grounds, and the judgment debt — however sound as a matter of English law — becomes effectively unreachable against Russian-domiciled assets.

The position is compounded by a structural difficulty specific to English court orders. Unlike arbitral awards issued under the rules of recognised international institutions, which benefit from the framework of the New York Convention, English court judgments do not enjoy automatic recognition in Russia. In the absence of a bilateral treaty on the reciprocal enforcement of judgments between the United Kingdom and Russia, recognition proceeds — where it proceeds at all — on the basis of the comity or reciprocity principle, which Russian courts have applied inconsistently. A time-barred application removes even that narrow avenue.

For a foreign creditor who has already traced Russian assets, missing the enforcement deadline creates a second-order problem: without a recognised judgment, interim asset-preservation measures tied to that judgment lapse, and dissipation risk increases materially. Creditors in this position should take legal advice immediately, as certain procedural routes — including fresh proceedings where the limitation clock may be argued differently, or enforcement in a third jurisdiction with a stronger treaty position vis-à-vis Russia — may remain available depending on the specific facts.

For a detailed procedural walkthrough, see Enforcing English court orders in Russia: a practitioner's briefing and the related legislative update on enforcement amendments. The firm's Asset Tracing & Recovery practice advises foreign creditors at each stage of this process.

If you are a foreign creditor with a Russian enforcement deadline approaching or already expired — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including trade creditors and institutional investors holding English court judgments — on enforcement strategy, interim relief applications, and asset recovery in Russia. 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/ 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

Russian civil procedure does not make legal representation mandatory for forensic accounting conducted in asset investigation proceedings. A foreign creditor may formally participate without a lawyer. In practice, however, an unrepresented party faces procedural disadvantages that can materially affect the recovery outcome.

Under Russian procedural law, court-ordered forensic accounting is an expert examination conducted under the court's supervision, available in both civil and commercial proceedings before Russian arbitrazh courts and general jurisdiction courts. The court selects and instructs the expert; parties may propose questions and review the resulting report. None of these steps require a qualified legal representative as a precondition of participation.

The absence of a formal requirement does not eliminate practical risk. Expert reports in Russian asset investigations are often technically dense and determinative of recovery outcomes. Challenging an expert's methodology or proposing supplementary questions requires procedural precision that Russian courts generally expect from qualified counsel. Foreign creditors who instruct the firm's Asset Tracing & Recovery practice [/practices/asset-tracing-recovery/] before the examination stage are better placed to shape the scope of the inquiry.

For a foreign creditor anticipating an asset investigation in Russia, early instruction of Russian legal counsel is the practical priority. Counsel retained before the forensic accounting stage is initiated can frame the questions put to the expert, monitor the process, and preserve grounds for challenge. See also: Supreme Court Enforcement Trends: Forensic Accounting in Asset Cases [/insights/atr-lu-019-supreme-court-enforcement-trend-forensic-acco/].

To discuss a Russian asset investigation matter — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors and institutional investors on enforcement, forensic evidence strategy, and distressed asset recovery across Russian courts. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

— 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Yes. Under Russian procedural law, decisions issued by arbitrazh courts in cross-border asset recovery proceedings are subject to a structured, multi-stage appeal hierarchy. A foreign creditor pursuing offshore asset recovery or coordinating parallel European and Russian enforcement proceedings should account for this hierarchy from the outset, as each stage carries distinct grounds and strict time limits.

Russian arbitrazh courts operate a four-tier review structure. A first-instance decision may be challenged before the appellate instance, then before the cassation court at circuit level, and – in exceptional cases involving fundamental errors of law – before the Supreme Court on cassation or supervisory review. Each tier applies its own standard of review: appellate review is broad; cassation review is confined to errors of law and procedure. Distressed assets held through Russian entities are fully subject to this scheme regardless of whether parallel European proceedings are on foot.

For a foreign creditor, the practical implication is symmetrical: the debtor may use the same routes to challenge a favourable recovery order, potentially delaying enforcement for months. Conversely, a creditor dissatisfied with a first-instance outcome – for instance, a dismissed asset-freezing application – retains the right to escalate. Timelines at the appellate and circuit cassation stages typically run to two to three months per tier, though this varies by circuit and caseload. Coordinating these Russian appeal windows with concurrent European proceedings requires careful case management to avoid conflicting procedural positions.

For guidance on the full procedural sequence, see Asset Tracing & Recovery and the companion briefing Foreign Creditors and Cross-Border Asset Recovery.

To discuss appeal strategy in a live Russian asset recovery matter — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

— Elizaveta Razina Senior Lawyer, Practice Lead – Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

Elizaveta Razina leads the firm's intellectual property and asset recovery practice, representing foreign creditors in enforcement and tracing proceedings before Russian state courts. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

Vetrov & Partners is a boutique Russian law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors and institutional investors on enforcement, freezing orders, and coordinated cross-border recovery proceedings before Russian arbitrazh courts. 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.

Indian creditors pursuing assets in Russia can search the Unified State Register of Legal Entities (EGRUL) to confirm a debtor company's registered status, directors, and shareholders. The Rosreestr property register identifies real estate and land holdings. Both registries are accessible through official public portals, but they reveal only directly registered assets — indirect holdings, pledged assets, and recent disposals require deeper analysis.

Under Russian civil and corporate legislation, legal entities are required to maintain current registration data in EGRUL, administered by the Federal Tax Service. Real property must be registered with Rosreestr under the state real estate register (EGRN). Insolvency filings and creditor claims are published on EFRSB — the federal register of insolvency information — which is also publicly accessible. Together, these three sources form the baseline of any corporate registry search Russia creditors conduct at the outset of a recovery.

For Indian creditors, the practical limitation is that EGRUL and Rosreestr disclose the legal position at the moment of search, not historical transfers or layered nominee structures. A debtor may have restructured its shareholding or transferred assets to related parties before enforcement commenced. Russian procedural rules permit challenges to such transfers, but identifying them requires cross-referencing multiple registries and, where necessary, court-ordered disclosure. A coordinated approach — combining EGRUL, Rosreestr, and EFRSB data — is described in the firm's overview of Russian corporate registry searches for asset tracing.

Indian creditors should conduct registry searches at the outset of any asset tracing and recovery strategy in Russia, before limitation periods become a live issue, and obtain a coordinated search report covering all three registers.

To discuss a corporate registry search or asset tracing matter in Russia — 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 and asset protection practice, representing foreign creditors and trademark owners in proceedings before Russian state courts. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Under Russian law, the Unified State Register of Real Estate — maintained by Rosreestr (the Federal Service for State Registration, Cadastre and Cartography) — is the authoritative source of record for ownership of land, residential and commercial property across Russia. For foreign creditors pursuing individual debtors, it is typically the first and most reliable investigative tool for establishing what real property assets a debtor holds.

The legal framework for accessing Rosreestr data in enforcement and investigative contexts operates through two principal channels. First, a court-appointed bailiff (судебный пристав-исполнитель) conducting enforcement proceedings has statutory authority to request Rosreestr disclosures directly, without further judicial authorisation. The bailiff's request covers current ownership data, encumbrances, and historical transfer records for property registered in the debtor's name across all Russian regions. Second, a court may issue an order for disclosure of Rosreestr data as part of interim relief or asset-freeze proceedings — typically used where enforcement has not yet commenced but the creditor has grounds to believe a debtor is dissipating assets. Russian civil procedure provides for such disclosure in the context of securing a claim.

Direct third-party access to Rosreestr records is restricted. A foreign creditor acting without a Russian enforcement title and without an engaged bailiff cannot obtain full ownership information for a named individual simply by submitting a request. Partial data — such as whether a specific address is registered to a named person — may be available through Rosreestr's public enquiry service, but comprehensive portfolio disclosure requires either an active enforcement file or a court order. In practice, foreign creditors instruct Russian counsel to initiate or support enforcement proceedings precisely to activate the bailiff's disclosure powers.

The practical value of Rosreestr data extends beyond establishing current ownership. Transfers completed within a defined period prior to insolvency or enforcement may be subject to challenge as preferential or fraudulent transactions — making the historical register data a starting point for transaction-avoidance analysis as well.

To discuss how Rosreestr disclosure can be used in your enforcement matter, make an enquiry: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

Further reading: Asset Tracing & Recovery | Rosreestr as an investigative tool — practice briefing

— 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Russian law provides Indian creditors with court-driven mechanisms to trace bank accounts and financial flows within Russia, though banking secrecy rules mean that disclosure is available through formal proceedings rather than voluntary disclosure or pre-action discovery. For a trade creditor seeking recovery from a Russian counterparty, understanding these mechanisms before initiating proceedings is the practical starting point.

Under Russian banking legislation, credit institutions are prohibited from disclosing account information to third parties without the account holder's consent or a legal basis under federal law. That legal basis, for a creditor, arises primarily through court proceedings. Once a claim is filed before a Russian arbitrazh court and interim relief is sought, the court may order the Federal Bailiff Service or the bank itself to disclose account information and freeze funds. Separately, a creditor who has already obtained a judgment can instruct the bailiff service to send information requests directly to Russian banks, which are obliged to respond within the statutory timeframe.

For Indian creditors specifically, the practical entry point is typically a substantive claim in a Russian arbitrazh court, or the enforcement of a foreign arbitral award issued in India or at an international institution. Russia is a signatory to the New York Convention, which means a validly obtained arbitral award can serve as the basis for enforcement proceedings in Russia – and enforcement proceedings carry the same disclosure tools as domestic litigation. Financial flows connected to the debtor, including intercompany transfers and payments through intermediary entities, can also be examined by the court-appointed enforcement officer when a judgment has been obtained.

One practical note: tracing efforts are more effective when initiated early, before a Russian counterparty has had the opportunity to restructure its accounts or route funds offshore. Indian creditors who suspect dissipation of assets should consider whether interim measures – including an account freeze – can be sought simultaneously with the main claim.

For a detailed overview of the procedural steps available to foreign creditors in Russian courts, see the firm's Asset Tracing & Recovery practice page.

To discuss tracing bank accounts and financial flows in Russia for your matter — 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 and asset protection practices. She has represented foreign creditors and rights-holders in enforcement proceedings before Russian state courts and advises on cross-border asset tracing strategy.

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.

Russian law provides US creditors with several mechanisms to challenge and unwind shell company structures that have Russian elements, though the process requires navigating overlapping branches of civil, insolvency, and procedural law — and the practical outcome depends heavily on how the structure was assembled and when the creditor acts.

The legal basis draws on three interlocking areas. First, Russian civil law prohibits transactions that constitute an abuse of rights or are entered into purely to harm creditors — a principle applied by Russian courts to transactions that transfer assets through artificial intermediaries. Second, where the Russian element is a company that has entered insolvency proceedings, Russian insolvency legislation provides a mechanism for subsidiary liability: controlling persons — including those who directed the structuring of assets through shell entities — may be held personally liable for the company's debts. Third, Russian procedural rules permit creditors to apply to the arbitrazh court for interim asset-preservation orders, which can freeze assets held in the name of nominally separate legal persons where a court is persuaded that the structural arrangement is artificial.

For a US creditor, the practical implication is this: unwinding a shell company structure with Russian elements is not a single proceeding — it typically involves coordinated steps across the Russian arbitrazh courts and, depending on where other elements of the structure sit, potentially foreign jurisdictions as well. The evidentiary threshold for demonstrating that a structure was constructed to defeat creditor claims is meaningful; Russian courts expect documentary evidence of the connection between the controlling person, the shell entities, and the original debtor. Without early-stage asset tracing, that evidence is rarely assembled in time to be effective. See our analysis of unwinding shell company structures with Russian elements and the Asset Tracing & Recovery practice page for further detail on the procedural landscape.

The recommended first step for a US creditor is to commission a Russian asset-tracing exercise before initiating proceedings. This establishes which assets remain within reach of Russian courts, maps the ownership chain of the shell structure, and identifies whether insolvency has been — or is likely to be — filed by the debtor. Acting before a voluntary insolvency petition is filed typically preserves a broader range of creditor remedies.

To discuss your position as a US creditor with Russian-element exposures — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

— Elizaveta Razina Senior Lawyer, Practice Lead — Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

Elizaveta Razina leads the firm's intellectual property and asset tracing practice, representing foreign creditors and rights holders in proceedings before Russian state courts. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including US-based institutional and trade creditors — on locating, preserving, and recovering assets through Russian civil and insolvency proceedings. 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.

Russian courts now look through Cyprus holding layers to reach individual debtors directly. Since Russia suspended the double-taxation treaty with Cyprus in August 2023 — following the earlier denunciation process initiated in 2022 — and as Russian arbitrazh courts have progressively applied substance-over-form doctrine in enforcement proceedings, a Cypriot intermediate holding company no longer reliably insulates an individual's Russian assets from a creditor's claim. Foreign creditors pursuing individual debtors through Cyprus-Russia corporate structures should expect Russian courts to examine the economic reality of the ownership chain rather than its formal legal appearance.

The legal basis sits at the intersection of three bodies of Russian law. First, under Russian civil legislation, courts may disregard a corporate entity and impose liability on the individual controlling it where the entity is found to have been used as an instrument of abuse of rights — a principle applied with increasing regularity since 2022 in creditor-side proceedings before arbitrazh courts. Second, under Russian insolvency legislation, the subsidiary liability (subsidiarnaya otvetstvennost) mechanism allows creditors to bring controlling persons — including individuals who held Cypriot intermediate entities — into personal liability in bankruptcy proceedings. Third, following the suspension of the Russia-Cyprus double-taxation agreement, the tax transparency justification that historically underpinned many Cyprus-Russia structures has materially weakened, removing one layer of legitimacy from such arrangements in the eyes of Russian regulators and courts.

In practice, this means that individual debtors who placed Russian assets beneath a Cypriot holding layer face a materially higher exposure than before 2022. Russian courts have, in documented proceedings, issued interim asset-freezing orders (obespechitelnye mery) targeting both the Russian operating entities and assets registered in the name of those entities, on the basis that the individual debtor retained beneficial control. The procedural avenue available to a foreign creditor depends on the type of claim: a creditor with a foreign arbitral award will approach recognition and enforcement in a Russian arbitrazh court; a creditor without an existing award will typically need to commence substantive proceedings in Russia or rely on a parallel insolvency filing.

The recommended next step for a foreign creditor is to instruct Russian counsel to conduct a preliminary asset-tracing analysis — mapping the current registered ownership of Russian-sited assets, identifying any interim measures already filed by other creditors, and assessing which procedural route (enforcement, insolvency, or direct claim) is most likely to yield recovery against the individual debtor within the available timeline.

If you are a foreign creditor seeking to enforce against an individual debtor through a Cyprus-Russia structure — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Russian law permits a creditor holding a valid enforcement title to instruct bailiffs to identify and levy execution on foreign assets — including UAE real estate held by a Russian national — though recovery in practice requires a separate recognition step in the UAE courts.

Under Russian legislation on enforcement proceedings, a bailiff is empowered to issue requests to identify a debtor's assets both within Russia and abroad. Where a Russian national holds registered real estate in the UAE, the bailiff may formally record that asset in the enforcement file and request that the debtor voluntarily comply with the judgment. Because Russia and the UAE have not concluded a bilateral treaty on mutual recognition of court judgments, the Russian enforcement title does not operate directly against UAE-registered property. The creditor must present that title — together with the Russian court decision underlying it — to the UAE courts and obtain a separate UAE recognition order before local enforcement measures, such as freezing or forced sale, can be applied to the property.

In practice, this two-stage process means that creditors who obtain an enforcement title in Russia early in the proceedings are better placed to move quickly before a debtor has the opportunity to transfer or encumber the UAE asset. Timelines vary considerably depending on UAE court workload and the completeness of documentation presented, but the existence of a Russian enforcement file does create a formal record that supports the UAE application. Detailed analysis of the regulatory framework is set out in our UAE real estate regulatory update (vetrovpartners.com/insights/atr-lu-006-regulatory-update-uae-real-estate-owned-by-ru/) and in our creditor-side briefing on UAE-held assets (vetrovpartners.com/insights/atr-pb-006-foreign-creditors-and-uae-real-estate-owned-b/).

Creditors with a Russian judgment should take early advice on both the Russian enforcement proceedings and the UAE recognition strategy simultaneously — delay in either limb can allow the debtor time to act. For a structured assessment of your recovery position, consult the firm's Asset Tracing & Recovery practice page (vetrovpartners.com/practices/asset-tracing-recovery/).

Make an enquiry — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on identifying and enforcing against Russian-nexus assets across multiple jurisdictions, with direct partner involvement on every matter. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

— 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, parallel import controls, and asset protection mandates with a cross-border dimension.

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.

For foreign creditors in the FMCG and retail sector, coordinating enforcement across Russia and foreign jurisdictions presents a structural challenge that differs materially from most cross-border recovery situations: debtor entities are often layered across Russia, a CIS member state, and one or more EAEU jurisdictions, while the most realisable assets — trade receivables, branded stock, distribution rights — move continuously and do not sit still for enforcement.

The Russian legal framework for asset tracing and enforcement gives arbitrazh courts broad powers to identify and freeze assets held by Russian entities, including receivables owed by domestic retail chains and inventory held in bonded or domestic warehouses. Where a debtor's structure extends to EAEU or CIS member states, the mutual recognition framework that applies between those states provides a procedural pathway — though its practical reliability varies by jurisdiction and requires confirmed local counsel in each seat.

The sector-specific complication for FMCG and retail creditors is that the most valuable assets are frequently encumbered, rotated, or transferred to related entities before enforcement measures can be completed. Russian courts have demonstrated willingness to set aside transactions that dissipate assets against creditors' interests, but the window for doing so is time-sensitive and depends on early action — which, in turn, depends on parallel tracking of asset movement across jurisdictions from the outset of the matter, not after domestic enforcement has stalled.

Coordinating enforcement effectively across Russia and foreign jurisdictions therefore requires a single point of legal coordination across all seats, with instruction given simultaneously rather than sequentially. For FMCG and retail matters specifically, this means briefing Russian counsel and any relevant foreign counsel at the same time, aligning interim relief applications, and establishing an agreed asset-mapping protocol before the first enforcement step is taken in any jurisdiction.

For further context on how Russian courts approach enforcement coordination, see Court practice: coordinating enforcement across jurisdictions and our Asset Tracing & Recovery practice page.

If you are a foreign creditor in the FMCG or retail sector seeking to coordinate enforcement across Russia and linked jurisdictions — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

A worldwide freezing order granted by a foreign court does not bind Russian courts directly. Russia has not acceded to treaties providing for automatic recognition of foreign interim relief. At the cross-border tracing stage, a creditor holding a worldwide freezing order against Russian-situated assets must therefore pursue two parallel tracks: enforcing disclosure obligations within the WFO jurisdiction, and conducting an independent Russian asset identification and restraint process. Each track has its own procedural logic, and delay on either one carries real dissipation risk.

The first track — operating within the WFO jurisdiction — involves using the order to compel disclosure from the respondent and from third parties holding assets or information on their behalf. This is typically handled by lead counsel in the issuing jurisdiction. The information obtained feeds directly into the Russian track.

The second track — the Russian asset freeze and tracing stage — proceeds as follows. Asset identification begins with searches of publicly accessible Russian registries: Rosreestr for real property and mortgage interests, the EGRUL corporate registry for shareholdings and directorships, and the bailiff service database for existing enforcement proceedings. These searches are accessible to any party without a Russian court order and form the evidential foundation for subsequent steps.

Once assets are identified, a creditor seeking interim restraint must apply for securing measures (обеспечительные меры) before a Russian arbitrazh court. This application is ordinarily filed simultaneously with, or immediately after, commencing substantive proceedings in Russia. Russian courts assess securing measure applications on an expedited basis, but the application must demonstrate a real risk of asset dissipation — not merely assert it. Courts have broad discretion on this question, and the strength of the supporting evidence materially affects the outcome.

For foreign creditors who have not yet commenced Russian proceedings, the window between obtaining the WFO and the respondent's awareness of it is often the only realistic opportunity to act. Creditors who allow that window to close without initiating Russian steps risk finding assets dissipated or transferred before any Russian restraint order is in place.

For specific guidance on cross-border tracing of Russian assets and coordinating worldwide freezing order strategy with Russian interim relief, see Worldwide Freezing Orders and Russian-Situated Assets and A Practical Guide to Worldwide Freezing Orders in the Russian Context.

The firm's Asset Tracing & Recovery practice advises foreign creditors at each stage of this process, including registry searches, securing measures applications, and coordination with lead counsel in the WFO jurisdiction.

If you are holding a worldwide freezing order and need to identify or restrain Russian-situated assets — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Korean creditors pursuing asset recovery against a Russian counterparty face a structurally distinct challenge: the enforcement steps available under Russian law – seizing accounts, enforcing pledges, or filing a creditor claim in Russian insolvency proceedings – may intersect with US Office of Foreign Assets Control (OFAC) restrictions in ways that are not always visible at the outset. Understanding where Russian law ends and OFAC jurisdiction begins is the starting point for any coherent recovery strategy.

Russian law provides several routes for a foreign creditor seeking to recover against a Russian debtor. Enforcement through the arbitrazh court system, registration as a creditor in Russian insolvency proceedings, and pledge enforcement over Russian-situated assets are all available in principle to a Korean claimant. Russian courts do not, as a general rule, distinguish between the nationality of a creditor when assessing procedural standing. The relevant question under Russian law is whether the claim is valid, timely, and properly documented.

The OFAC dimension arises separately and is governed by US law, not Russian law. Korean entities conducting transactions in US dollars, maintaining correspondent banking relationships with US institutions, or operating subsidiaries incorporated in the United States may fall within OFAC's jurisdiction even when the underlying dispute is entirely between Korean and Russian parties. In that situation, certain steps in a recovery strategy – for instance, receiving funds through a sanctioned Russian bank – could create compliance exposure under US law regardless of whether the recovery itself is lawful under Russian law. Korean creditors who delay obtaining a US-law analysis of their specific situation risk discovering this intersection only after a critical enforcement step has already been taken.

Vetrov & Partners advises on the Russian-law dimension of cross-border recovery: establishing the creditor's claim before Russian courts, protecting asset positions during insolvency proceedings, and structuring enforcement steps under Russian procedural rules. We do not advise on OFAC compliance or US sanctions law. For the OFAC element, Korean creditors should instruct US-qualified sanctions counsel at an early stage – ideally before any enforcement action is initiated in Russia.

If you are a Korean creditor evaluating a Russian asset recovery strategy, make an enquiry regarding the Russian-law dimension: 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 and asset protection practice, representing foreign creditors and rights holders in proceedings before Russian state courts. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Russian law treats digital assets, including cryptocurrency, as property subject to enforcement proceedings against individual debtors. Under Russian digital asset legislation, creditors may apply to a court for interim measures to freeze a debtor's holdings. Once a judgment is obtained, enforcement authorities hold procedural competence to execute against those assets. Identifying and tracing digital assets in Russia typically requires exchange disclosure orders or blockchain analysis, with Russian-regulated exchanges obliged to respond to court-sanctioned requests. The legal framework is in place; practical implementation continues to evolve.

Russian digital asset legislation, which came into force in 2021, classifies digital currency as property that can be owned and enforced against under the standard civil execution framework. Russian courts have increasingly granted interim freezing orders over cryptocurrency held at domestic exchanges, treating such assets on the same basis as other personal property.

For individual debtors, the Federal Bailiff Service holds formal competence to enforce against identified digital assets, though execution against self-custodied wallets remains procedurally underdeveloped in Russian practice. Creditors who delay initiating enforcement proceedings risk losing priority if a debtor transfers or liquidates digital holdings before a freeze order is in place.

Foreign creditors should engage specialist Russian counsel before a debtor has had the opportunity to move holdings. The firm's Asset Tracing & Recovery (/practices/asset-tracing-recovery/) practice advises on the full enforcement sequence. See also: Navigating digital asset and cryptocurrency tracing in Russia (/insights/atr-pb-010-navigating-digital-asset-and-cryptocurrency-t/).

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 and asset protection practices, representing foreign creditors and trademark owners in proceedings before Russian state courts and the IP Court. She has been with the firm since 2012 and advises on tracing and enforcement strategy for foreign creditors pursuing individual debtors in Russia.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors on locating and enforcing against Russian-held assets, including digital assets and cryptocurrency, across enforcement and insolvency proceedings. 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.

Foreign companies and creditors with interests in Russian oil and gas are required to identify, document, and disclose their beneficial owners under Russian anti-money laundering legislation, and failure to comply carries direct consequences for Russian asset recovery — including the risk of regulatory intervention that can precede or obstruct creditor enforcement proceedings.

Under Russian law, any legal entity operating in Russia — including those in the oil and gas sector — must identify individuals who ultimately own or control the entity through a direct or indirect interest of 25 per cent or more, or who exercise effective control by other means. This information must be maintained in an internal register and disclosed to authorised bodies on request. The Federal Financial Monitoring Service (Rosfinmonitoring) is the principal oversight authority, acting alongside sector regulators and the Federal Tax Service in matters touching subsoil use rights and oil and gas licences.

For foreign creditors holding security over shares in Russian subsoil licence holders, or over the assets of operating oil and gas companies, the practical risk is this: beneficial ownership disclosure gaps in the debtor's corporate structure can trigger administrative sanctions and, in more serious cases, asset-level measures that may complicate or delay enforcement. Entities incorporated in EAEU member states are subject to equivalent obligations where they hold Russian assets or operate through Russian subsidiaries. The rules apply regardless of the foreign creditor's own jurisdiction.

Foreign clients assessing recovery options in this sector should verify beneficial ownership compliance as part of any pre-enforcement due diligence on the target company. Non-compliance by the target is not a creditor problem per se, but regulatory action triggered by that non-compliance can affect the assets a creditor is seeking to recover.

For a fuller analysis of the legislative framework, see Beneficial Ownership Disclosure Obligations under Russian Law and the related legislative amendment briefing. The firm's Asset Tracing & Recovery practice advises foreign creditors on pre-enforcement due diligence and recovery strategy in Russia.

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 and recovery work involving IP-adjacent asset protection questions.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors on beneficial ownership analysis, pre-enforcement due diligence, and recovery proceedings in Russia. 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.

Under Russian civil legislation, nominee arrangements — structures in which one party holds assets, shares, or contractual rights formally in their name on behalf of another — are not recognised as a distinct legal category conferring enforceable rights. Where a Korean creditor encounters such an arrangement when tracing Russian assets, Russian law offers two principal routes to challenge it. The first is the simulated transaction doctrine, which recharacterises the nominee relationship to reveal the underlying agreement. The second is the fictitious transaction doctrine: a transaction entered without genuine intent to create legal consequences is declared void. Both carry retroactive effect and are available in Russian court proceedings.

Under Russian civil legislation, any interested party — including a foreign creditor — may apply to a Russian court for recharacterisation or nullification of a nominee arrangement. In insolvency proceedings, additional challenge rights arise for the insolvency manager and the creditors' committee within defined look-back periods before the bankruptcy filing. Russian courts assess the economic substance of the arrangement: the conduct of the parties, the financial flows, and any documentary record that contradicts the formal structure. The burden of proof lies with the challenging party, and evidentiary thresholds vary by circuit, so early document preservation is essential.

For Korean creditors, the practical risk is clear. Nominee structures in Russia are frequently used to obscure real estate, corporate shares, or receivables from foreign enforcement. A creditor who identifies nominee indicators — disproportionate beneficial conduct, absence of consideration, connected-party flows — and delays challenge risks losing priority over key assets once insolvency is filed. At that stage, the estate is administered on the registered legal position, and recovery options narrow materially.

For advice on nominee arrangement risks and unwinding strategies in Russia, Korean creditors are welcome to make an enquiry at info@vetrovpartners.com or contact the team on WhatsApp / Telegram at +7 (983) 510-38-76. Further practice analysis is available on the Asset Tracing & Recovery practice page [/practices/asset-tracing-recovery/] and at How Russian courts approach nominee arrangements [/insights/atr-pb-012-how-russian-courts-approach-nominee-arrangeme/].

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

Elizaveta Razina leads the firm's intellectual property and asset protection practice. She advises foreign creditors and rights-holders on asset tracing, nominee structure challenges, and enforcement proceedings before Russian state courts.

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.

Under Russian civil law, a foreign creditor pursuing asset recovery may seek to challenge transfers made by a debtor before or after proceedings commence — but the analysis differs materially depending on whether the challenge is brought within insolvency proceedings or through a standalone civil action. At the interim relief stage, understanding which legal pathway is available is often the factor that determines whether a freezing application will succeed.

Russian civil legislation distinguishes between two principal routes for challenging potentially fraudulent transfers. Outside insolvency, a creditor may seek to void a transaction under the general provisions of the Civil Code governing transactions concluded to the detriment of creditors. Within insolvency proceedings, Russian insolvency legislation provides a dedicated framework for avoidance actions, offering broader grounds and longer look-back periods. The interim relief available to a creditor — and the standard the court will apply when assessing a freezing application — depends directly on which route is engaged and at what stage the application is made.

At the freezing and interim relief stage, the practical challenge for foreign creditors is evidentiary. Russian arbitrazh courts apply a well-established two-part test: the applicant must demonstrate both a prima facie case on the underlying claim and a real risk that enforcement of any future judgment will be frustrated. Where the creditor can show a pattern of asset disposals — transfers to connected parties, undervalue transactions, or encumbrances placed on key assets shortly before or after the dispute arose — courts are more likely to grant interim measures. Evidence of such transfers, gathered through Rosreestr property searches, corporate registry analysis, and transaction tracing, forms the analytical foundation of any freezing application. That said, Russian courts retain broad discretion and interim measures are not routinely granted; the threshold in practice is higher than in many Western European jurisdictions.

For foreign creditors who have identified suspicious transfers, the recommended step is to instruct Russian counsel before filing any claim, so that the fraudulent transfer analysis can be prepared alongside the interim relief application — the two must be presented together to have the strongest prospect of success.

For advice on asset tracing and interim relief strategy in Russia, visit our Asset Tracing & Recovery practice page or make an enquiry directly.

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/

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.

Indian creditors pursuing recovery against a Russian debtor may apply for interim relief – including asset-freeze orders and property attachment – in Russian courts at any stage of proceedings, and in some circumstances before a claim is formally filed. Russian law does not impose special restrictions on creditors from India in accessing these remedies, and current procedural rules treat foreign creditors on an equal procedural footing with domestic applicants before the arbitrazh courts.

Under Russian civil procedure and arbitrazh procedure rules, interim relief applications in Russian courts are assessed against two principal criteria: the applicant must demonstrate that the underlying claim is arguable, and that failure to preserve the asset would render any future judgment unenforceable or materially more difficult to execute. Russian courts may grant an asset-freeze order within a single business day of receiving the application where the evidentiary basis is clear and the risk of dissipation is documented. In practice, the strength of the asset-identification evidence and the speed of the application filing are the two factors that most consistently influence outcome.

For Indian creditors specifically, the absence of a formal bilateral enforcement treaty does not prevent access to interim relief measures in Russia – preservation and attachment orders are procedural remedies granted by Russian courts on their own motion authority, independent of any treaty framework. What matters in practice is that the application is filed promptly, that the assets to be preserved are identified with reasonable precision, and that the documents supporting the underlying claim are translated into Russian and certified in the manner recognised by Russian procedural rules. Delay is the principal risk: a debtor who becomes aware of impending proceedings may take steps to restructure or dissipate assets before an order is served.

For a creditor-side assessment of your specific recovery position in Russia – including whether interim relief is available for the assets you have identified – make an enquiry: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

Further reading on the procedural landscape: Court practice shift on interim relief applications and Key risk points in interim relief applications. For a broader overview of asset tracing and recovery procedures, visit the Asset Tracing & Recovery practice page.

— 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors – including those from India and the Asia-Pacific region – on asset-preservation applications, enforcement strategy, and recovery proceedings before Russian arbitrazh courts. 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.

Russian civil procedure does not contain a mechanism directly equivalent to a third-party disclosure order as understood in English or common-law proceedings. There is no provision permitting a creditor to compel a bank, accountant, or other third party to disclose information about a debtor's assets as a freestanding interim remedy in the way that Norwich Pharmacal or Bankers Trust orders operate. Foreign creditors pursuing asset tracing and recovery in Russian proceedings at the freezing and interim relief stage should treat disclosure as an ancillary procedural tool rather than an independent cause of action.

The framework governing disclosure in Russian civil and arbitrazh proceedings rests on two distinct mechanisms. First, a court may, on application by a party, issue a formal request to a third party – including a bank, state registry, or regulatory authority – to produce documents or information relevant to the proceedings. This is the judicial evidence request procedure, available in both general jurisdiction and commercial (arbitrazh) court proceedings. Second, at the interim relief stage, the court's power to secure a claim includes the ability to prohibit third parties from performing acts that would dissipate disputed assets. A third party served with a securing order is legally obliged to comply and to refrain from any transaction that the order specifies. Neither mechanism, however, compels unsolicited asset disclosure by third parties in advance of or independent from substantive proceedings.

In practice, foreign creditors seeking information about a Russian debtor's assets at the freezing stage have three main routes available. A court-issued inquiry to Rosreestr, the Federal Tax Service, or the Central Bank can yield property, tax registration, and banking relationship data – but only once proceedings are on foot and the court has jurisdiction. If the debtor holds assets offshore or through layers of Russian holding structures, the evidential picture at the interim stage will often be incomplete; courts in Russia do not routinely make sweeping disclosure orders against third parties equivalent to a full asset disclosure order under English law. The more effective approach for foreign creditors is to secure the claim first – obtaining a freezing order over identifiable Russian assets – and then to use the evidence request procedure in parallel to broaden the asset picture. Our longer analysis of this area is set out in Third-Party Disclosure Orders in Russian Proceedings: A Legal Update and the accompanying Practical Guide to Third-Party Disclosure Orders. The firm's Asset Tracing & Recovery practice page sets out how the firm approaches these matters for foreign creditors.

For foreign creditors with live recovery proceedings in Russia, understanding the limits of the disclosure framework before applying for interim relief materially affects the strategy. Applying for a freezing order over assets that have not yet been identified carries procedural risk; equally, delaying the interim application while evidence is gathered may allow dissipation. Make an enquiry to discuss your matter in confidence: 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 and asset protection practice, representing foreign creditors and rights holders in enforcement and tracing proceedings before Russian state courts and the IP Court. She has been with the firm since 2012.

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.

Foreign creditors seeking to enforce against Russian mining and metals operators frequently consider directing letters rogatory — formal requests for judicial assistance — at Russian state authorities. The practical utility of this mechanism under Russian law is narrower than foreign counsel often assume, and the sector introduces specific institutional complications.

Russian courts and authorities handle incoming letters rogatory under two frameworks: treaty-based channels and Russian domestic civil procedure where no applicable treaty exists. Russia is a party to the 1993 Minsk Convention on Legal Assistance in Civil, Family, and Criminal Matters, which applies among CIS member states. Russia is not a party to the 1970 Hague Convention on the Taking of Evidence Abroad — a channel that practitioners familiar with common-law jurisdictions may expect to use. Requests arriving outside a treaty basis are processed, where accepted at all, through diplomatic channels and subject to significant delay.

In the mining and metals sector, letters rogatory are most commonly directed at three Russian authorities. The Federal Agency for Subsoil Use (Rosnedra) maintains the state register of subsoil licences. Rosreestr holds title records for immovable production assets and land plots. The Federal Tax Service holds corporate registry and financial data on operating entities. Each authority applies its own procedural rules; the scope of information disclosable is defined by Russian law, not by the requesting court's evidentiary standards. Rosnedra treats certain licence data as commercially sensitive, and responses are typically limited to publicly available register extracts.

Creditors should expect processing timelines of several months even under treaty frameworks. They should also verify at the outset whether the relevant Russian entity or asset falls within a sector subject to strategic subsoil classification, which may restrict disclosure further.

For an overview of asset tracing mechanisms available to foreign creditors in Russia, see the firm's Asset Tracing & Recovery practice and the related briefing International letters rogatory directed at Russian authorities.

If you are tracing assets against a Russian mining or metals operator — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors and distressed investors seeking to identify, preserve, and enforce against Russian-sited assets. 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/

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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

Foreign creditors holding freezing or interim relief orders against Russian assets face a two-layer constraint that is frequently underestimated at the litigation planning stage: the freeze itself restricts disposition of the asset by the respondent, but Russian currency control legislation imposes an independent, separate set of restrictions on whether a foreign party can actually transfer the value of that asset out of Russia once the dispute is resolved in the creditor's favour. These two legal regimes operate in parallel, and satisfying one does not satisfy the other.

Russian currency regulation legislation requires that most cross-border transfers involving Russian residents – or assets located in Russia – proceed through authorised channels and, in many cases, obtain prior approval from the Central Bank of Russia or comply with general or individual permits. The scope of what qualifies as a "currency operation" under Russian law is broad and encompasses not only cash transfers but also assignments of rights, debt set-offs, and certain asset-linked payment arrangements. For creditors from jurisdictions designated under Russian regulatory frameworks as unfriendly, additional restrictions introduced by presidential decrees in recent years apply on top of the general currency control regime, limiting or effectively prohibiting certain categories of outbound transfer absent a special government commission approval.

At the freezing and interim relief stage specifically, the practical consequence is that interim measures preserve the asset for enforcement purposes but do not create a pathway for repatriation. A creditor who secures an asset freeze in Russian arbitrazh proceedings has not yet resolved the currency control question. Depending on the structure of the underlying asset – whether it is a receivable, real estate, a share in a Russian legal entity, or cash in a Russian bank account – the route to repatriation, and the regulatory authorisations required, will differ materially. Planning for this divergence at the interim measures stage, rather than at enforcement, is the more disciplined approach.

Foreign creditors navigating Russian interim relief should therefore ensure that the recovery strategy addresses currency control compliance as a standalone workstream from the outset. In practice, this means mapping the asset type, the creditor's jurisdiction of residence, the applicable regulatory permits, and any available exemptions under intra-EAEU arrangements where the creditor's structure or the debtor's counterparties involve EAEU member states.

To discuss a recovery strategy that accounts for both freezing procedure and Russian currency control requirements, 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 and asset protection practice, representing foreign clients in proceedings before Russian state courts and the IP Court. She advises on asset tracing and recovery strategy, including currency control compliance in cross-border enforcement 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.

Enforcing an English court order in Russia against a state-related entity is procedurally possible but practically constrained. Russian courts do not operate under a bilateral recognition treaty with the United Kingdom, which means recognition turns on the principle of reciprocity under Russian civil procedure law – a standard that Russian courts have applied inconsistently and, in recent years, restrictively. Foreign creditors pursuing this route should understand the procedural sequence and the additional immunity layer that state-related respondents can invoke.

A foreign creditor seeking recognition and enforcement of an English judgment in Russia must first file a petition with the competent Russian arbitrazh court – typically the court at the respondent's place of registration or the location of its assets. The petition must be accompanied by a certified and apostilled copy of the judgment, a certified Russian translation, and documentary evidence that the judgment is final and enforceable in England. The court will then assess whether reciprocity exists between Russia and the United Kingdom as a matter of current judicial practice, not treaty obligation. This assessment is discretionary, and outcomes vary by circuit.

Where the respondent is a state-related entity – a state-owned enterprise, a company with majority state participation, or an entity exercising public functions – the enforcement creditor must also navigate the question of state immunity. Under Russian law, state-related entities do not automatically enjoy sovereign immunity in commercial disputes, but in practice the boundary between commercial and sovereign activity is contested and can be raised as a procedural objection at the recognition stage. Creditors should anticipate this argument and prepare documentary evidence establishing the commercial character of the underlying transaction.

If the recognition application succeeds, the court issues an enforcement order (исполнительный лист), which is then presented to the Federal Bailiff Service (FSSP) for execution against the respondent's identified Russian assets. Locating and preserving those assets before or immediately after the recognition application is filed is, in practice, the critical step – particularly where the respondent has the means and the incentive to dissipate them.

For practical guidance on the broader enforcement framework, see the firm's Asset Tracing & Recovery practice page and the related briefing Enforcing English Court Orders in Russia: Practical Briefing.

Foreign creditors holding English judgments against Russian state-related entities should take early legal advice before the asset position changes. 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 and asset protection practice. She has represented foreign creditors and asset-holders in proceedings before Russian state courts and advises on cross-border enforcement strategy, including asset identification and preservation measures in the Russian Federation.

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.

Russian law contains no dedicated forensic accounting statute. For Turkish creditors seeking to trace assets in Russia, the discipline is regulated indirectly — through civil procedure rules governing court-appointed expert examinations, auditor engagement under Russian accounting legislation, and the disclosure mechanisms available in arbitrazh (commercial) court proceedings. In practice, forensic accounting work in a Russian asset investigation is channelled through two parallel tracks: a court-ordered financial expert examination, and pre-litigation analysis conducted by an independent auditor or financial consultant retained by the creditor's legal team.

The legal basis for forensic work in Russian courts rests on the civil procedure framework for expert evidence. A party or the court may commission a financial expert to analyse transaction flows, reconstruct accounting records, or assess the financial condition of a debtor at a specific date. Russian accounting legislation imposes record-keeping obligations on companies that create the documentary foundation such experts rely upon, and auditors are subject to professional standards that govern their methodology and reporting. There is no separate licensing category for "forensic accountant" under Russian law; practitioners operating in this space are typically qualified auditors or financial analysts whose conclusions are submitted as expert opinions in proceedings.

For Turkish creditors, the practical significance is this: forensic accounting analysis is most effective when initiated early — before assets are dissipated and while court-ordered disclosure remains a live enforcement tool. Turkish companies benefit from Russia's membership of the EAEU framework and its CIS treaty obligations, which in certain contexts facilitate cross-border recognition of financial documentation and co-operation requests. However, neither framework removes the requirement to work through Russian civil procedure when seeking enforceable findings in Russian courts. Creditors who approach forensic analysis as a purely documentary exercise, without anticipating the procedural requirements for admissibility in Russian proceedings, frequently find that their expert conclusions carry limited weight. For a detailed analysis of how Russian courts assess forensic accounting evidence, see How Russian courts approach forensic accounting evidence.

The recommended step for a Turkish creditor at the outset of a Russian asset investigation is to engage Russian legal counsel before commissioning any accounting analysis, so that the forensic methodology is designed with Russian procedural admissibility in mind from the start. The firm's Asset Tracing & Recovery practice advises creditors at this initial structuring stage.

To discuss a Russian asset investigation — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors — including Turkish trade creditors and institutional investors — on asset investigations and enforcement proceedings before Russian courts. Direct partner involvement on every engagement. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

— 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Cross-border asset recovery involving Russian assets typically requires four sequenced procedural stages: asset identification and freeze in Russia, parallel interim measures in the relevant European jurisdiction, recognition or enforcement of the primary judgment or award, and coordinated realisation of frozen assets. For Chinese creditors, each stage carries jurisdiction-specific requirements that must be addressed in a defined order — missteps at the freeze stage can render later enforcement steps ineffective.

Under Russian civil procedure and insolvency legislation, a creditor seeking to freeze Russian-sited assets must apply to the competent arbitrazh court for interim relief. The application must demonstrate a credible risk of dissipation and link the claimed sum to identifiable assets. Russian courts assess these applications on a creditor-side factual basis, and the standard for urgency is applied strictly. Separately, any foreign judgment or arbitral award relied upon will need to be formally recognised before Russian courts before execution can proceed — a process governed by Russian civil procedure rules and, for arbitral awards, by the New York Convention as implemented in Russia.

In practice, the critical sequencing issue for Chinese creditors is this: interim relief in Russia will not wait for European proceedings to conclude. Where assets are held across multiple jurisdictions, a creditor that secures a European freeze first — without a parallel application in Russia — risks the Russian-sited assets being moved in the intervening period. The firm's asset tracing and recovery practice advises on coordinating these applications so that Russian and European filings proceed within the same operational window.

For Chinese creditors with assets in both Russia and European jurisdictions, early-stage coordination between Russian counsel and European local counsel is the practical priority. See also our overview articles on cross-border asset recovery for foreign creditors and regulatory developments in cross-border recovery.

To discuss the sequencing of proceedings in your matter — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

Under bailiff-led enforcement in Russia, corporate registry searches are the primary mechanism by which the Federal Bailiff Service locates and identifies debtor assets held through legal entities. The process follows a structured sequence that begins at the moment an enforcement order is presented and proceeds through formal inter-agency data requests, with each registry disclosing a distinct category of asset or participation interest. Foreign creditors who understand this sequence can engage with the bailiff's office more effectively and identify gaps in the search that may require supplementary creditor-initiated action.

The Federal Bailiff Service holds statutory authority to send mandatory disclosure requests to Russia's principal registries as part of its enforcement mandate. In practice, the sequence as a general rule proceeds as follows.

The first stage covers the unified state register of legal entities, known by its Russian abbreviation EGRYUL, which discloses whether the debtor holds a participation interest – a share or equity stake – in any Russian legal entity. This is the foundational step for corporate registry searches under bailiff-led enforcement, since most structured Russian debtors hold assets through subsidiary or affiliate vehicles rather than directly.

The second stage covers Rosreestr, the federal register of immovable property, which identifies real estate assets registered to the debtor or to entities in which the debtor holds a disclosed interest.

The third stage covers the register of pledges over movable property, relevant where the debtor's assets have been pledged as security, potentially affecting the enforcement priority available to the creditor.

The fourth stage – increasingly significant for foreign creditors tracing offshore asset structures with a Russian footprint – covers the Federal Resource of Information (Fedresurs), which consolidates disclosures from insolvency proceedings and certain corporate events that may reveal asset movements prior to enforcement.

Taken together, these corporate registry searches in Russia produce a statutory asset map of the debtor's disclosed holdings. They do not, however, capture assets held through undisclosed nominee structures or transferred before the enforcement order was issued. Gaps of this kind typically require creditor-initiated supplementary searches, which fall outside the bailiff's statutory mandate.

For foreign creditors pursuing recovery through Russian enforcement proceedings, engaging qualified local counsel before the bailiff's search concludes allows the creditor to review interim registry results and direct supplementary tracing where the disclosed picture is incomplete. The Asset Tracing & Recovery practice at Vetrov & Partners advises foreign creditors at each stage of this process.

Make an enquiry — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on corporate registry searches, bailiff-led enforcement coordination, and supplementary tracing strategies under Russian law. 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/

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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

Under Russian law, the Rosreestr property register is one of the most reliable sources of information about a debtor's real property assets in enforcement proceedings. For a foreign creditor holding an enforceable judgment or award against a Russian debtor, Rosreestr – Russia's unified state register of rights to immovable property – provides title data that bailiffs and creditors' representatives can access through established mechanisms under Federal Law 229-FZ on enforcement proceedings to trace, verify, and support enforcement against registered real assets.

Federal Law 229-FZ on enforcement proceedings in Russia authorises the Federal Bailiff Service to send compulsory requests to Rosreestr to identify property registered in the debtor's name. Once enforcement proceedings are initiated by filing a writ of execution, the bailiff assigned to the case typically dispatches such requests to Rosreestr and other state registers within a short period after acceptance of the writ. The register response discloses registered real property – including land plots, buildings, apartments, and commercial premises – along with existing encumbrances, pledges, and the current registration status of any transfer or restriction. Creditors and their counsel may, in parallel, commission a paid extract from Rosreestr in respect of a named legal entity to confirm registered holdings before or during proceedings, which can support the grounds for interim protective measures at court.

For a foreign creditor, the practical value of Rosreestr lies in speed and reliability. The register is centralised and covers all Russian territory, so a single inquiry – whether by the bailiff or by counsel – can reveal real property across multiple regions. However, the register does not cover every category of asset: movable property, bank accounts, securities, and participatory interests in Russian companies require separate inquiries to other state bodies. A comprehensive asset-tracing strategy in Russia therefore combines Rosreestr data with inquiries to the Federal Tax Service, the traffic police register, and the corporate register of legal entities. See the firm's Asset Tracing & Recovery practice page for the full investigative framework, and the related briefing at Rosreestr property register as an investigative tool for procedural detail.

The recommended next step for a foreign creditor with an enforceable Russian title is to instruct counsel to verify the current Rosreestr position before enforcement commences, to assess whether any protective measures – such as a judicial prohibition on registration of transfers – should be sought to prevent the debtor from disposing of registered assets during proceedings.

To discuss asset tracing and enforcement strategy in Russia — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on identifying and enforcing against Russian-registered assets, combining Rosreestr register analysis with multi-register inquiry strategy across Russian federal districts. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

— 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 in matters involving registered property rights.

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.

Tracing bank accounts and financial flows in Russia against insolvency estates follows a defined procedural sequence under Russian insolvency legislation. The process is initiated through the arbitrazh court supervising the insolvency proceedings, and foreign creditors must act through, or in coordination with, the appointed insolvency manager.

The first step is inclusion in the creditors' register. A foreign creditor must submit its claim to the arbitrazh court within the statutory window after the commencement of insolvency proceedings. Creditors not registered cannot formally instruct or direct the insolvency manager or access procedural rights in the estate.

Once registered, creditors may raise requests at the creditors' meeting for the insolvency manager to conduct or expand financial investigations. The insolvency manager holds statutory authority to request bank account information, transaction histories, and counterparty data from Russian credit institutions. Banks are obliged to disclose this information to an appointed insolvency manager, without a separate court order in most cases.

Where the insolvency manager is uncooperative or where the scope of tracing requires disclosure beyond what the manager is willing to pursue, a registered creditor may apply directly to the arbitrazh court. The court may order the manager to take specified investigative steps, or may authorise direct access to financial records as part of judicial oversight of the insolvency process.

Interim asset-freeze applications – interim measures targeting specific accounts or flows identified through tracing – are available through the arbitrazh court and are typically sought in parallel once account data has been located. Timing is material: Russian insolvency legislation provides mechanisms to challenge pre-insolvency transactions, and the evidential basis built through tracing directly supports those applications.

Foreign creditors in Russian insolvency proceedings benefit from early legal counsel engagement, before the creditors' register deadline passes and before the insolvency manager's investigative agenda is set without their input.

For advice on tracing bank accounts and financial flows in Russian insolvency estates, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Further analysis of the procedural framework governing asset tracing in Russian insolvency is set out in Navigating Tracing of Bank Accounts and Financial Flows in Russia and Russian Supreme Court Clarification on Tracing. Related questions are addressed in What are the main procedural steps in Russian asset recovery? and How does Russian law regulate Rosreestr property searches?.

The Asset Tracing & Recovery practice page provides an overview of the firm's work in this area.

— 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Russian law subjects shell company structures with Russian elements in the pharmaceuticals sector to a layered unwinding framework that combines general corporate veil provisions, sham transaction doctrine, and sector-specific pharmaceutical licensing rules – and foreign creditors who approach recovery without accounting for all three layers typically encounter significant procedural obstacles.

Under Russian civil and corporate legislation, courts may disregard the separate legal personality of an intermediate holding entity where it is found to be a conduit with no genuine independent commercial function. The governing doctrine – commonly described in Russian legal practice as the "lifting of the corporate veil" – requires the claimant to demonstrate that the intermediate entity was used to conceal the true beneficial owner or to shield assets from creditors. This threshold is not easily met and typically demands contemporaneous documentary evidence of control, funds flows, and decision-making. Where a transaction forming part of the shell structure can be characterised as a sham under Russian law, courts have the power to declare it void and restore the parties to their prior positions – subject to bona fide third-party purchaser protections that frequently complicate asset recovery.

In the pharmaceuticals sector, an additional dimension arises: pharmaceutical licences, marketing authorisations, and registration certificates held by a Russian entity cannot be transferred or re-attributed to a creditor or liquidator as an incidental consequence of unwinding the ownership structure. The regulatory authority responsible for pharmaceutical oversight in Russia – Roszdravnadzor – retains control over licence continuity, and any restructuring that touches the licensed entity requires advance regulatory engagement. For a foreign creditor seeking to recover value from a pharmaceutical distributor or manufacturer, this means the recoverable asset pool may be practically constrained even where the unwinding claim itself succeeds.

Foreign creditors should therefore conduct a two-stage assessment before commencing any unwinding proceedings: first, map the full ownership chain to identify where Russian-law entities sit and what assets are held at each level; second, obtain an early-stage analysis of whether pharmaceutical licences constitute a material share of the target's value and what regulatory steps would be required to preserve that value through the recovery process. Delay in initiating proceedings can erode both the strength of the unwinding claim and the practical recoverability of pharmaceutical assets if licence continuity lapses.

If you are a foreign creditor tracing assets through a Russian-element shell structure in the pharmaceutical sector, the firm's asset tracing and recovery practice can provide an initial assessment of the unwinding framework applicable to your matter: 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy, parallel import controls, and, in conjunction with the firm's asset tracing practice, on asset recovery matters involving IP-adjacent structures.

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.

Foreign creditors holding enforceable Russian titles against debtors whose assets are held within Cyprus-Russia corporate structures now face a materially more complex enforcement path than existed before 2022 – and Federal Law 229-FZ on enforcement proceedings remains the procedural backbone through which that recovery must run. The reorganisation of Cypriot holding layers, driven by regulatory pressure, DTT termination, and direct-ownership mandates, has altered where assets sit and who formally owns them. Under 229-FZ, the enforcement sequence begins with the creditor presenting an enforcement writ to the Federal Bailiff Service, which then maps, seizes, and liquidates the debtor's Russian assets. Where those assets are shares or participatory interests in a Russian entity that has undergone post-2022 restructuring, the tracing step – confirming current registered ownership through the State Register of Legal Entities and Rosreestr – has become the critical gateway before any seizure order is effective.

The starting point for any foreign creditor is the enforcement writ itself. A Russian court judgment or arbitral award recognised by a Russian court produces a writ of execution (ispolnitelny list), which the creditor or its counsel presents to the territorial division of the Federal Bailiff Service (FSSP) with jurisdiction over the debtor's registered address or the location of its principal Russian assets. Under 229-FZ, the bailiff must initiate enforcement proceedings within three days of receiving the writ and must notify the debtor, who then has a short voluntary compliance period – typically five days – before coercive measures apply.

Where the debtor is a Russian operating company that was formerly held through a Cypriot intermediate entity, post-2022 restructuring has commonly resulted in three scenarios relevant to enforcement: direct transfer of the Russian entity's shares to a Russian individual or entity (in which case 229-FZ enforcement against those shares proceeds on standard terms); transfer to a state trustee or management company under presidential decree authorisation (which may temporarily suspend or complicate 229-FZ-based seizure); or structural abandonment, where the Cypriot layer remains formally in place but is commercially inactive. In the third scenario, tracing actual recoverable value requires examining whether the Russian subsidiary retains operating assets independently and whether those assets appear in the FSSP asset search.

Asset identification under 229-FZ is conducted through a bailiff-initiated enquiry to Rosreestr (real property), the State Automobile Inspectorate (vehicles), the Federal Tax Service register (bank accounts), and the State Register of Legal Entities (corporate participatory interests and shares). For Cyprus-Russia structures post-2022, the practical complication is that ownership records may reflect intermediate restructuring steps that are not yet fully updated – a gap that experienced Russian counsel can exploit through parallel direct registry enquiries and corporate document requests under Russian civil procedure.

Once assets are identified and not subject to a prior encumbrance or regulatory restriction, the bailiff issues an attachment order. Shares in a Russian limited liability company (OOO) or joint-stock company (AO) are attached by the bailiff notifying the company's register administrator. Real property is attached via Rosreestr notation. Bank accounts are frozen through direct instruction to the relevant bank. Creditors who have appointed Russian counsel with active FSSP relationships can monitor the progress of each step in real time, which in practice significantly accelerates a process that, without counsel involvement, can stall at the asset-identification stage for months.

For advice on enforcing a Russian judgment or arbitral award against assets held within a Cyprus-Russia corporate structure,

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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

At the cross-border tracing stage, the principal steps for a foreign creditor seeking to enforce against UAE real estate held by a Russian national are: (1) establishing Russian-side authority through a Russian court or arbitral award; (2) identifying and documenting the UAE asset through available tracing channels; and (3) engaging UAE proceedings — typically before the DIFC Courts or onshore UAE courts — to convert that Russian-law entitlement into enforceable UAE relief. Each stage carries its own procedural requirements, and the sequencing matters: attempting enforcement in the UAE without first consolidating the Russian-law position typically prolongs the overall process.

The Russian-side foundation rests on Russian civil procedure and, where insolvency is engaged, on Russian insolvency legislation. A Russian arbitrazh court can issue interim measures — including freezes on foreign-held assets where grounds exist under the applicable procedural rules — and can provide certified documentation of a debt, judgment, or claim that UAE proceedings will later require. At the tracing stage specifically, Russian counsel can assist in compiling asset-disclosure evidence, coordinating with Russian notarial and registry channels, and preparing court-certified translations for use abroad. It is important to note that direct judicial cooperation between Russia and the UAE under bilateral treaty instruments is limited; in practice, creditors generally rely on UAE proceedings running in parallel with or immediately following Russian-side steps, rather than on automatic recognition of Russian court orders.

For creditors with UAE real estate in scope, the practical implication is that the cross-border tracing stage is not a single-jurisdiction exercise. UAE real estate owned by Russian nationals typically sits in one of three structural layers — direct individual title, UAE company ownership, or a trust or foundation structure — and the tracing approach, and therefore the enforcement option available, differs materially across these layers. Creditors who attempt UAE enforcement without first resolving which structural layer applies routinely encounter delays at the UAE courts that could have been avoided by investing in the tracing exercise at the outset.

For Asset Tracing & Recovery matters involving UAE real estate, see also our regulatory update at atr-lu-006 and our creditor-focused briefing at atr-pb-006. Related FAQ: What are the main procedural steps in Russian asset tracing?

To discuss a cross-border tracing matter involving UAE real estate, 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, parallel import controls, and asset identification in cross-border recovery matters.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on identifying, documenting, and enforcing against Russia-linked assets across multiple jurisdictions, with partner-direct involvement at every stage. 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.

At the enforcement proceedings stage, coordinating enforcement across Russia and foreign jurisdictions requires a sequenced approach — not a simultaneous one. Russian law enforcement proceedings operate through the Federal Bailiff Service and, where assets require court involvement, through the arbitrazh courts. These mechanisms run independently of foreign enforcement orders: Russian courts do not automatically give effect to foreign judgments or freezing orders, and foreign courts typically have no direct reach over assets held within Russia. A creditor who proceeds without mapping this gap risks obtaining orders in multiple jurisdictions that do not reinforce one another in practice.

Under Russian civil enforcement rules, the governing framework for enforcement proceedings in Russia treats each asset class — bank accounts, real property, shares, receivables — as subject to distinct procedural steps before the bailiff service or the court. Coordinating enforcement across Russia and abroad therefore means sequencing those steps against the parallel timetable of foreign proceedings, taking account of where recoverable assets are actually located. An offshore asset held through a Russian operating entity may be susceptible to enforcement in Russia while a foreign parent entity holds other assets reachable by a foreign court — but the orders must be timed to avoid dissipation.

A sequencing error at this stage — for example, initiating enforcement in one jurisdiction before securing a precautionary measure in the other — can give a debtor sufficient notice to move or encumber assets before either order bites. In practice, the safest approach is to identify, before proceedings commence, which jurisdiction holds the most immediately reachable assets and anchor the enforcement sequence there, using the other jurisdiction as a secondary track.

The practical priority for foreign creditors is to instruct Russian-qualified counsel and foreign counsel jointly, establishing a shared enforcement timeline before any step is taken in either jurisdiction. Vetrov & Partners' asset tracing and recovery practice [/practices/asset-tracing-recovery/] advises creditors on cross-border enforcement sequencing in Russia and coordinates with trusted local counsel in relevant foreign jurisdictions. For related procedural context, see our analysis of court practice shifts in coordinating enforcement [/insights/atr-lu-007-court-practice-shift-on-coordinating-enforcem/] and the key risk points practitioners should anticipate [/insights/atr-pb-007-key-risk-points-in-coordinating-enforcement-a/].

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.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on enforcement proceedings in Russia, cross-border coordination, and asset identification across the Siberian and Ural federal districts. 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.

Russian law does not recognise or directly enforce worldwide freezing orders issued by foreign courts. A foreign FMCG or retail creditor seeking to protect Russian-situated assets — stock in a distribution warehouse, trade receivables from a retail chain, or real property held by a Russian subsidiary — must apply for interim relief through Russian domestic proceedings entirely independently of any foreign order. The existence of a worldwide freezing order obtained in London, Amsterdam, or Nicosia carries no legal force before a Russian arbitrazh court and will not, by itself, prevent a Russian counterparty from dissipating those assets.

Under Russian civil and arbitrazh procedure, interim measures are available on application to the court that will hear the substantive dispute, or — where arbitration has been agreed — to the competent state court in support of those proceedings. The applicant must demonstrate that without interim relief, enforcement of a future judgment or award would be impossible or substantially impaired. Russian courts assess this threshold independently; a foreign court's prior finding that a freezing order is warranted is not binding and is rarely persuasive in practice.

For creditors in the FMCG and retail sector specifically, the assets most commonly targeted include registered trade marks (traceable through Rospatent), distribution agreements and accounts receivable, retail leasehold interests, and inventory held at third-party logistics providers. Each asset class requires a distinct attachment mechanism under Russian procedural law. A single application framed as an equivalent of a WFO will not succeed; the attachment must be asset-specific and supported by evidence of the asset's existence and location.

For a detailed procedural account, see Worldwide Freezing Orders and Russian-Situated Assets and the firm's Asset Tracing & Recovery practice page.

If you hold a worldwide freezing order and need to protect Russian-situated FMCG or retail assets — 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, parallel import controls, and asset-specific attachment proceedings involving IP and distribution assets in the FMCG and retail sector.

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.

When a foreign creditor's Russian asset recovery strategy in the pharmaceuticals sector intersects with OFAC sanctions, the operative question is not whether an OFAC licence removes all constraints, but which Russian-law procedural steps remain available within the compliance envelope established by US counsel.

The short answer is that Russian civil procedure, insolvency law, and interim relief mechanisms operate independently of OFAC's administrative framework. OFAC designations may block the transfer of funds or assets to or from a sanctioned party under US jurisdiction, but they do not suspend Russian court proceedings, eliminate a creditor's right to file a claim, or extinguish a pledge or security interest under Russian law. The two regimes run in parallel and must be managed in parallel.

In practice, the principal Russian-law procedural steps that remain available — and that foreign pharmaceutical creditors frequently overlook while awaiting OFAC licence determinations — are: first, preserving limitation periods by filing a claim in the relevant Russian arbitrazh court before the Russian statutory period expires, independent of OFAC status; second, registering any security interest or pledge with the relevant Russian registry to protect priority against competing creditors; third, applying for interim asset preservation measures (обеспечительные меры) from the arbitrazh court, which can freeze Russian-domiciled assets without requiring any transfer of value and therefore without triggering OFAC transfer prohibitions; and fourth, filing a creditor's claim in any insolvency proceeding the Russian counterparty may initiate, since failure to file within the statutory window permanently extinguishes priority. In pharmaceutical sector matters specifically, regulatory licences, product registration certificates, and intellectual property held by the Russian counterparty may constitute recoverable assets under Russian law that are not themselves directly within OFAC's scope.

The practical risk for foreign creditors is that OFAC licence processing timelines — which may extend well beyond 12 months for complex general licences — can cause Russian limitation periods to lapse if no protective steps are taken in Russian courts in the meantime.

For advice on coordinating OFAC compliance with a live Russian asset recovery strategy in the pharmaceuticals sector, see also OFAC Sanctions Intersection with Russian Asset Recovery Strategy — Practice Briefing and the Asset Tracing & Recovery practice page. For the Russian-law dimension of asset recovery more broadly, see What are the main procedural steps in Russian asset recovery?.

If your Russian pharmaceutical counterparty holds recoverable assets and OFAC compliance is complicating your recovery timeline — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including those operating in regulated sectors — on Russian-law enforcement steps, interim relief, and creditor-side insolvency strategy. 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/

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 asset protection strategy and has been with the firm since 2012.

Under Federal Law 229-FZ on enforcement proceedings, Russian bailiffs — the Federal Bailiff Service — now have a defined procedural pathway to locate, freeze, and recover digital assets and cryptocurrency held by a judgment debtor. For foreign creditors pursuing recovery in Russia, understanding this sequence is a practical priority, because the window between a court order and a debtor's transfer of cryptocurrency offshore can close within hours.

The enforcement procedure begins when a claimant presents a valid enforcement instrument — typically an arbitrazh court judgment or a confirmed arbitral award — to the territorial division of the Federal Bailiff Service. The bailiff issues an enforcement order and opens proceedings, at which point the debtor's assets across all known classes, including digital assets, become subject to measures of compulsory execution.

Identification and disclosure form the first substantive step. The bailiff sends mandatory information requests to financial institutions, digital asset exchange operators, and other custodians that may hold or have information about the debtor's digital assets. Where the debtor holds cryptocurrency through a self-custodied wallet, the bailiff may compel the debtor to disclose private keys or wallet access credentials as part of the obligation to comply with enforcement. Refusal carries liability under administrative law and may support an application to the court for indirect enforcement measures.

Once identified, the relevant digital assets are subject to arrest — a legal freeze preventing the debtor from transferring or disposing of them. The bailiff formalises the arrest in a resolution and, where custody arrangements permit, coordinates with exchange operators or custodians to implement the hold. The arrested assets are then valued in accordance with market price at the date of arrest, using officially recognised pricing sources.

Realisation — converting the arrested digital assets to rouble proceeds — follows valuation. This step is conducted through specialist organisations authorised to conduct electronic trading, or through regulated exchange platforms. The proceeds are distributed to the creditor in priority order under the enforcement proceedings rules, with the creditor's principal debt satisfied ahead of accrued penalties and enforcement costs. See our Asset Tracing & Recovery practice overview and the analysis at Navigating Digital Asset and Cryptocurrency Tracing in Russia for detailed treatment of each stage.

One practical caution: the procedural framework under Federal Law 229-FZ applies to assets held through custodial arrangements or identifiable on-chain addresses. Self-custodied assets where the debtor is uncooperative present additional evidentiary challenges, particularly where the debtor denies holding any digital assets at all. Courts have addressed this issue with growing frequency — for recent judicial developments see Russian Supreme Court Clarification on Digital Asset Enforcement.

Foreign creditors with a Russian enforcement instrument who believe the debtor holds digital assets should act promptly. The Asset Tracing & Recovery team at Vetrov & Partners advises creditors on initiating and monitoring enforcement proceedings, coordinating with the Federal Bailiff Service, and applying for interim measures where urgency requires.

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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Under Russian law, beneficial ownership disclosure obligations in the context of bailiff-led enforcement arise from the intersection of two distinct legal regimes — the statutory framework governing enforcement proceedings administered by the Federal Bailiff Service (FSSP) and the corporate legislation requiring Russian legal entities to identify, record, and disclose their beneficial owners on demand from authorised bodies.

Russian enforcement legislation grants bailiffs broad powers to compel disclosure of a debtor's assets, financial accounts, and corporate participations. In practice, this means a bailiff executing against a Russian debtor entity may formally request information from state registries — including Rosreestr (for immovable property), the Federal Tax Service (for corporate shareholding and tax records), and credit institutions. Where the debtor holds participations in other legal entities, the chain of ownership becomes material to locating assets available for recovery. It is through this chain-tracing function that beneficial ownership information enters the enforcement process, though the FSSP's direct access to formal UBO register data held by corporate compliance departments remains subject to procedural constraints that vary in practice across circuits.

Russian corporate law separately requires legal entities to know their beneficial owners — defined, broadly, as the natural persons who ultimately own or control the entity through direct or indirect participation or otherwise. Companies must maintain internal records and disclose this information to authorised state bodies on request. Under the anti-money laundering framework, Rosfinmonitoring holds a supervisory role in this area. A creditor cannot directly compel a debtor company to produce its UBO register as a standalone enforcement step — the formal route runs through the bailiff's information requests to state bodies and through targeted asset-tracing applications to the arbitrazh court supervising the enforcement proceedings.

For a foreign creditor holding a Russian court judgment or an arbitral award recognised in Russia, the most effective approach to beneficial ownership disclosure under bailiff-led enforcement typically combines a formal FSSP execution with parallel applications to the arbitrazh court for judicial assistance in obtaining information — including from registries and, where justified, from the debtor entity directly. Timelines for information responses from state registries in enforcement proceedings generally range from several weeks to several months, depending on the registry and the complexity of the corporate structure involved.

For detailed guidance on the broader procedural framework, see Asset Tracing & Recovery and the related briefing on beneficial ownership disclosure obligations under Russian law.

If you are a foreign creditor seeking to trace assets or compel beneficial ownership disclosure through Russian enforcement proceedings — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Russian law gives foreign creditors concrete tools to challenge nominee arrangements concealing assets held by individual debtors, though the process requires prompt action and well-documented evidence of the arrangement's artificial character.

Under Russian civil legislation, transactions that lack genuine legal substance – including those structured to place assets beyond a creditor's reach through a nominee – may be challenged as sham or simulated transactions. Where an individual debtor has transferred property to a nominee without genuine economic purpose, a creditor may apply to a Russian court to have the arrangement unwound, restoring the asset to the debtor's estate. Russian insolvency legislation extends this further: where the debtor is subject to personal insolvency proceedings, the insolvency administrator may pursue contestation of transfers made to nominees within defined look-back periods, and the courts have generally been willing to examine the substance of the arrangement rather than its formal title. Separately, a creditor may seek an interim asset freeze – an обеспечительная мера – at the outset of proceedings to prevent dissipation while the unwinding claim is pursued.

For a foreign creditor, the practical exposure is the gap between the moment a nominee structure is identified and the moment enforcement is secured. Russian courts require evidence that the nominee held the asset without genuine independent ownership – documentary, transactional, and often witness-based – and the standard of proof is higher when the debtor contests the claim actively. In the Siberian and Ural circuits, courts have generally scrutinised nominee arrangements rigorously where asset transfers preceded financial difficulties, though outcomes vary with the specifics of each matter.

Foreign creditors who suspect a nominee arrangement is concealing recoverable assets should seek Russian legal advice before initiating any enforcement step, as the sequencing of an asset freeze application and the unwinding claim materially affects the prospect of recovery.

To discuss nominee arrangement risks and recovery options against an individual debtor in Russia – make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For further reading on the asset tracing and recovery framework, see the firm's Asset Tracing & Recovery practice page, and the related analyses at FAS Russia enforcement trends and nominee arrangements and How Russian courts approach nominee arrangements.

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

Elizaveta Razina leads the firm's intellectual property practice and advises on asset protection and tracing matters. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

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.

What should foreign clients know about fraudulent transfer analysis

When a Russian debtor strips assets through pre-arranged transfers just before or during bailiff-led enforcement, Russian civil law provides a creditor with a route to challenge those transactions in court and bring the transferred assets back within reach.

Under Russian civil law, courts may recognise a transfer as invalid where it was made in bad faith, without adequate consideration, or in circumstances indicating an intent to defeat a creditor's claim. This analysis applies whether the debtor is a natural person or a legal entity. The claim is pursued as a separate civil action before the competent court, not as an application within the bailiff proceedings themselves. Courts assess the timing of the transfer, the relationship between the transferor and transferee, the value exchanged, and whether the debtor was or became insolvent at the relevant time. Transactions involving connected parties or transfers offshore attract heightened scrutiny.

For a foreign creditor operating under bailiff-led enforcement in Russia, the practical implication is significant: discovering that the debtor has shifted key assets does not necessarily mean those assets are permanently beyond reach. A timely application to freeze the transferred assets, filed alongside the invalidation claim, can preserve the recovery position while litigation proceeds. Delays in bringing the challenge are, however, material — Russian courts typically apply limitation periods strictly, and a creditor who waits too long may lose standing to pursue the claim at all.

The recommended first step is to obtain a comprehensive asset map — identifying what was transferred, to whom, and when — before commencing proceedings. The firm's Asset Tracing & Recovery practice advises foreign creditors on this analysis, including cross-referencing registry records, corporate filings, and enforcement dossiers compiled by the Federal Bailiff Service. Further analysis on the substantive framework is set out in Fraudulent Transfer Analysis: Regulatory Update and in Foreign Creditors and Fraudulent Transfer Analysis.

If you are a foreign creditor pursuing recovery under Russian enforcement and have identified suspicious asset movements, 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

A foreign creditor pursuing an individual debtor through a Russian court of general jurisdiction may apply for interim relief at any stage of the proceedings — including simultaneously with filing the statement of claim. Russian courts assess such applications ex parte and are required to rule on them, as a general rule, on the day they are received, without notifying the debtor in advance. The measures available against individual debtors include the freezing of bank accounts, the arrest of movable and immovable property, a prohibition on the debtor concluding transactions affecting specific assets, and — in cases meeting the applicable threshold — a travel restriction preventing the debtor from leaving the Russian Federation.

Procedurally, the application must be accompanied by the statement of claim (or filed together with it) and supported by evidence that, absent the measures, enforcement of a future judgment would be impossible or materially more difficult. The court is not required to hear oral submissions before granting relief; the written record governs. If the application is granted, the court issues a ruling that is immediately enforceable: the creditor receives a writ of execution and transmits it to the Federal Bailiff Service (FSSP), which registers and enforces the freeze on the same day or the next working day in standard cases.

For a foreign creditor, the practical implications are significant. The window between filing and the debtor's discovery of the freeze is narrow — often a matter of hours — which is precisely the feature that makes interim relief applications in Russian courts against individual debtors a useful tool in cross-border asset recovery. Any delay in submitting a complete application package, however, risks alerting the debtor through ancillary proceedings before the arrest is in place.

To discuss the procedural requirements in your specific matter, make an enquiry: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76

For broader context on interim relief strategy, see Court practice shift on interim relief applications and Key risk points in interim relief applications. The firm's Asset Tracing & Recovery practice page sets out the full range of enforcement tools available to foreign creditors in Russia.

— 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013).

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm advises foreign creditors on asset tracing, interim relief, and enforcement in Russian courts. 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.

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.

For a German creditor seeking to obtain evidence or asset information from Russian authorities through an international letter rogatory, the procedure unfolds across four principal stages — each governed by Russian civil procedure rules and, where applicable, the bilateral legal assistance treaty between Germany and Russia.

The first stage is transmission. The requesting German court issues the letter rogatory and forwards it through the designated central authority — typically the German Federal Office of Justice — which transmits the document to Russia's Ministry of Justice. This diplomatic channel is required: direct court-to-court transmission is not accepted under Russian procedural rules for incoming foreign requests.

The second stage is examination for formal compliance. Once received by the Russian Ministry of Justice, the request is reviewed for completeness, proper authentication, and conformity with Russian public policy. Documents must be accompanied by a certified Russian-language translation. Requests that are incomplete, unauthenticated, or that conflict with Russian law are returned without execution — a step that can set the timeline back materially.

The third stage is referral to the competent Russian court or authority. If the request passes the Ministry's review, it is forwarded to the appropriate arbitrazh court or court of general jurisdiction, or to the relevant state registry (such as Rosreestr for property records or the Federal Tax Service for certain financial data), depending on the nature of the information sought.

The fourth stage is execution and return. The Russian court or authority executes the request in accordance with Russian procedural rules — not the rules of the requesting court — and transmits the result back through the same ministerial channel to Germany. In practice, the total timeline from transmission to receipt of results commonly extends to several months, and Russian courts exercise discretion over the scope of execution.

For German creditors, the letters rogatory route is one of several mechanisms for tracing Russian assets. It operates in parallel with direct enforcement proceedings before Russian courts and with the use of local counsel to request court-ordered disclosure within Russian insolvency or recovery proceedings. Our Asset Tracing & Recovery practice note on this instrument provides further procedural detail.

Related reading:

• Rospatent guidance on international letters rogatory and IP asset evidence
• International letters rogatory directed at Russian authorities: a practitioner overview
• Main procedural steps in Russian civil enforcement for foreign creditors

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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Foreign creditors seeking to trace and recover assets held by a Russian debtor must navigate two distinct legal frameworks that are frequently conflated: Rosreestr (the state registry for real property and certain secured interests) and the corporate registry maintained by the Federal Tax Service, known as the EGRUL. Alongside these registry tools, Russian currency control regulations — which have been subject to significant restriction in recent years — govern whether recovered funds can actually leave Russia. Understanding all three frameworks is essential before enforcement proceedings begin.

Rosreestr is the Federal Service for State Registration, Cadastre and Cartography. It holds title records for real estate, land plots, and certain registered encumbrances — pledges, mortgages, and restrictions on disposal. A creditor seeking to identify a debtor's Russian real property assets can request an extract from Rosreestr. Basic title information is accessible, though access to fuller encumbrance and ownership data has been subject to procedural restrictions in recent periods; as a general rule, instructing Russian counsel to obtain an official extract with an authorised request yields the most complete picture.

The EGRUL — the Unified State Register of Legal Entities — is held separately by the Federal Tax Service, not by Rosreestr. It records the registered address, director, shareholder structure, and charter capital of Russian legal entities. For a foreign creditor assessing where a debtor's corporate interests sit, EGRUL extracts can surface participation in subsidiaries, affiliated entities, and recent changes in ownership that may signal asset movement. Publicly available data can be retrieved online; a full certified extract requires a formal request.

Russian currency control regulations present a separate and, in current conditions, more complex challenge. Under Russian currency legislation, the transfer of funds abroad by Russian residents — and in certain respects by non-residents holding Russian accounts — is subject to authorisation requirements and, under currently applicable restrictions, a range of limitations on capital outflows. Foreign creditors who obtain a favourable Russian court judgment and seek to repatriate the recovered sum should expect that currency transfer will require engagement with the authorised bank servicing the account from which payment is made. The available currency transfer routes, applicable limits, and documentation requirements have changed on multiple occasions since 2022, and the position should be confirmed with Russian counsel at the time of enforcement.

For a foreign creditor in active enforcement, the practical sequence is: (1) conduct Rosreestr and EGRUL searches to map the debtor's recoverable assets before initiating proceedings; (2) assess the currency control position at the outset of the matter, not at the point of recovery; and (3) obtain current guidance on authorised transfer channels, since the regulatory position remains subject to amendment.

The firm's Asset Tracing & Recovery practice advises foreign creditors on the full sequence — from registry-based asset mapping through to enforcement and repatriation analysis. You may also find useful context in our analysis of Russian Supreme Court clarifications on asset recovery and our guide on navigating asset repatriation and Russian currency controls.

Make an enquiry — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

About Vetrov & Partners

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors — including institutional investors and trade creditors — on Russian registry searches, enforcement proceedings, and cross-border recovery strategy. 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/

Elizaveta Razina leads the firm's intellectual property and asset protection practice. She advises foreign creditors and trademark owners on Russian registry procedures, asset tracing, and enforcement proceedings before Russian state courts.

English court orders — including freezing injunctions and disclosure orders — have no automatic recognition or enforcement mechanism in Russia at the pre-action investigation stage. Russia and the United Kingdom have no bilateral treaty on the mutual recognition of civil judgments or pre-trial interim orders. An English freezing order cannot be served on Russian registries or banks through Russian courts to compel compliance; it is not self-executing in the Russian legal system. For a foreign creditor holding such an order, this means that Russian-based assets of the debtor remain outside the reach of the English order until separate steps are taken in Russia.

Under Russian civil procedure law, the mechanism for pre-action asset preservation is an independent application for interim measures — referred to in Russian arbitrazh procedure as обеспечительные меры — filed directly with the competent Russian arbitrazh court. A creditor can seek a Russian asset freeze before a final judgment, provided the application demonstrates that failure to grant interim relief will render future enforcement impossible or materially more difficult. This standard is applied by Russian courts with some variation across circuits, and the threshold for granting pre-action interim measures tends to be interpreted strictly. The English order itself is not a substitute for this application, though it can serve as supporting evidence of the underlying claim and the creditor's diligence.

In practice, a creditor enforcing English court orders in Russia at the pre-action investigation stage has three complementary tools available. First, publicly accessible property registries — including Rosreestr for real estate and the Federal Bailiff Service database — allow asset searches without any court involvement, providing a factual basis for any interim measures application. Second, where a valid arbitration clause exists, interim measures from a recognised Russian arbitration institution — such as the International Commercial Arbitration Court at the Chamber of Commerce and Industry (MKAS) — can be sought and are typically processed more efficiently than through state court procedure. Third, for the gathering of evidence from persons in Russia, the Hague Convention on the Taking of Evidence Abroad in Civil or Commercial Matters offers a formal channel, though Russia's reservations limit its scope and timelines in practice commonly extend to twelve months or more.

The recommended next step for a creditor at this stage is to instruct Russian counsel to conduct a preliminary asset search and assess the grounds for an independent interim measures application before the debtor has the opportunity to dissipate Russian assets. Delay at the pre-action stage frequently translates into a narrower recovery outcome. Vetrov & Partners advises foreign creditors on asset tracing and recovery matters in Russia, including pre-action investigation strategy, interim measures applications, and co-ordination with foreign counsel holding English court orders. Related guidance is available in our articles on enforcing English court orders in Russia — practice briefing and on legislative amendments affecting enforcement of English court orders.

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 asset tracing strategy and recovery matters, including pre-action investigations and interim measures applications in Russian arbitrazh courts.

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.

At the freezing and interim relief stage in Russian asset investigations, forensic accounting is not a supplementary tool — it is the foundation on which a creditor's application stands or falls. Russian arbitrazh courts granting interim measures require the applicant to demonstrate, with documentary support, both the existence of a substantive claim and a real risk that assets will be dissipated before judgment. Forensic accounting provides the structured transactional analysis that satisfies this evidential threshold.

Under Russian procedural law governing interim measures, courts assess whether the applicant has established a prima facie case and whether the balance of convenience favours preservation of assets. A forensic accounting report — tracing transaction flows, identifying ultimate beneficiaries, and mapping asset structures across Russian entities and, where relevant, offshore holding layers — directly addresses both limbs of that test. Courts in the Siberian and Ural circuits have accepted forensic analysis as part of the documentary package supporting freezing applications, particularly where corporate structures obscure direct asset ownership.

For a foreign creditor pursuing asset recovery in Russia, the practical implication is sequencing. Forensic work should begin before the application is filed, not after. The evidential package submitted with the interim relief petition shapes the court's initial assessment, and a weak evidentiary foundation at this stage can be difficult to remedy once proceedings are under way. For context on how Russian courts have applied forensic evidence in enforcement matters, see Supreme Court enforcement trend: forensic accounting and How Russian courts approach forensic accounting.

The recommended next step for creditors with Russian counterparty exposure is to instruct counsel to assess the available documentary base — corporate records, transaction histories, and known asset registers — before determining whether the evidentiary threshold for a freezing application can be met. Our Asset Tracing & Recovery practice advises foreign creditors at each stage of this process.

If you are assessing whether forensic accounting supports an interim relief application against a Russian counterparty — 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 has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.

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.

Foreign creditors pursuing cross-border asset recovery in Russia must initiate and manage two parallel tracks simultaneously: bailiff-led enforcement proceedings before the Federal Bailiff Service (FSSP) in Russia, and whatever local enforcement mechanisms apply in the European jurisdiction where the debtor also holds assets. Neither track suspends or substitutes for the other.

Under Russian law, enforcement of a court judgment or a recognised arbitral award against a debtor's Russian-sited assets proceeds through the FSSP. Once an enforcement order (ispolnitelny list) is issued by the court, the FSSP opens enforcement proceedings and has the authority to freeze bank accounts, attach movable and immovable property, and compel the debtor to disclose its assets. Crucially, the FSSP's jurisdiction is territorial: its powers extend only to assets located in Russia. Assets held in Germany, the Netherlands, or elsewhere in Europe remain entirely outside its reach.

This territorial limitation is the central coordination challenge in cross-border asset recovery. A creditor who obtains a freeze on Russian assets through the FSSP has no guarantee that the debtor will not have already moved liquid funds out of Russia before the enforcement order takes effect. Parallel injunctive relief in the relevant European jurisdiction — sought concurrently, not sequentially — is therefore essential for creditors seeking to trace assets across Russia and European jurisdictions simultaneously.

In practice, coordinating Russia and European proceedings requires counsel admitted in both systems working to a shared timetable. Timing is material: Russian limitation periods and procedural deadlines run independently of European court schedules. A delay in commencing Russian enforcement proceedings while awaiting a European court order can result in the permanent loss of available assets in Russia.

For foreign creditors holding a judgment or award enforceable in Russia, the recommended first step is an asset-tracing assessment — establishing where the debtor's Russian assets are sited and their approximate realisable value — before committing enforcement resources to either track. This assessment shapes the sequencing and resource allocation for the full cross-border recovery strategy.

Further analysis of the Russian procedural framework is available in the firm's Asset Tracing & Recovery practice overview and in the related briefing on foreign creditors and cross-border asset recovery.

To discuss a cross-border asset recovery matter or request an initial assessment — 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 and recovery mandates.

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.

In advising foreign creditors on the recovery of Russian assets, a pattern recurs with uncomfortable regularity: the creditor arrives with a judgment or arbitral award in hand, a company name on a contract, and the assumption that Russian corporate registry data will map a clean path to recoverable assets. That assumption is correct in structure and dangerously incomplete in practice. Russian corporate registry searches — primarily through EGRUL, the unified state register of legal entities — are a necessary starting point for any asset tracing exercise under Russian law. They are not sufficient. Understanding what these registries reveal, what they conceal, and how their output interacts with the wider Russian legal framework is the difference between a productive enforcement strategy and an expensive false start.

Russia maintains several public and semi-public registries relevant to asset tracing. EGRUL — the Unified State Register of Legal Entities — is the primary source for corporate data. It records incorporation details, registered address, principal activity codes, directorship, and — critically for creditors — the composition of participants (shareholders) in a limited liability company or the share structure of a joint-stock company. A parallel register, EGRIP, covers individual entrepreneurs. Both are administered by the Federal Tax Service.

Beyond EGRUL, the asset tracing toolkit encompasses Rosreestr for real property and long-term land leases; the State Traffic Safety Inspectorate (GIBDD) database for registered vehicles; and EFRSB — the Unified Federal Register of Bankruptcy-Related Information — for insolvency proceedings, creditor claims, and asset realisations. Intellectual property rights are traceable through Rospatent. Pledge registrations over movable property are held in the notarial pledge register.

Each registry has a distinct access regime, a distinct scope, and distinct limitations. EGRUL data is publicly available without charge and downloadable in bulk XML format. Rosreestr data requires a paid extract and has, in practice, experienced periodic restrictions on the disclosure of personal data associated with individual property owners. EFRSB is publicly searchable but presents results in a format that demands legal interpretation to be useful.

For a foreign creditor conducting corporate registry searches in Russia, the first practical step is to establish which registries are likely to hold responsive data for the specific debtor profile — legal entity, individual entrepreneur, or natural person — before any search request is submitted.

The EGRUL extract for a Russian limited liability company (ООО) will typically disclose: the full legal name and registered address; the date of registration and assigned taxpayer identification number (INN); the general director (sole executive body); and the list of participants with their nominal shareholding percentages. For joint-stock companies, the shareholder register is held separately by a licensed registrar and is not reflected in EGRUL — a point that creditors relying on EGRUL alone consistently overlook.

Nominal shareholding data is precisely that: nominal. EGRUL records the legal ownership structure as filed. Beneficial ownership — the natural person who exercises ultimate economic control — is not systematically disclosed in EGRUL. Russia has developed beneficial ownership reporting obligations under anti-money laundering legislation, but the resulting data is held by obliged entities and the Federal Financial Monitoring Service (Rosfinmonitoring), not disclosed publicly through EGRUL. A creditor searching EGRUL will see the immediate registered shareholders; identifying the ultimate beneficial owner requires a separate investigative layer.

Corporate registry searches in Russia are further complicated by the availability of nominee structures. While Russian law imposes restrictions on nominee arrangements, the practical effect of those restrictions depends on enforcement, which has been uneven. A chain of Russian holding companies, or a structure in which the immediate shareholder is itself a company registered in a CIS or EAEU jurisdiction, may be visible in EGRUL as a single entry point without revealing the asset pool behind it. Tracing that chain requires cross-referencing EGRUL data with registry searches in other EAEU member-state jurisdictions — an exercise that demands local counsel in each relevant jurisdiction.

For foreign creditors assessing Russian corporate structures before initiating enforcement, early registry analysis can determine whether the visible asset base justifies proceedings — and identify the gaps that will define the litigation risk. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

A creditor approaching Russian corporate registry searches today encounters a materially different access environment from that which existed before mid-2022. Amendments to Russian legislation on the protection of personal data, together with Federal Tax Service and Rosreestr administrative decisions, have progressively restricted the public disclosure of personal data in registry extracts. The practical effect is significant.

Rosreestr extracts for property registered in the name of an individual now, in many cases, disclose the fact of registration without disclosing the owner's identifying details. A creditor can establish that a specific property address is registered to an unnamed individual — but cannot confirm from the extract alone whether that individual is the debtor. Confirmation requires either a court order compelling disclosure, an application through a bailiff executing an enforcement instrument, or a formal request through the Federal Bailiff Service as part of active enforcement proceedings.

EGRUL has been less affected in terms of corporate data. Directorship and participation data for legal entities remains accessible. However, the personal passport details and residential addresses of directors and participants — which were previously visible in EGRUL extracts obtained through professional access — are now withheld from standard public extracts. For asset tracing purposes, this removes a layer of data that was previously used to link individual beneficial owners across multiple corporate structures.

The net result is that corporate registry search Russia analysis, as of mid-2027, requires a two-stage approach: open-source registry extraction followed by formal legal process to fill the gaps. Neither stage is sufficient alone. A foreign creditor who completes the open-source phase and concludes that no recoverable assets exist may be drawing that conclusion from an incomplete dataset.

"The most consequential errors in Russian asset tracing arise not from what creditors find in the registries, but from what they assume the registries would show if assets were there." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For the foreign creditor seeking to enforce a Russian judgment or a recognised foreign arbitral award, registry data serves two distinct functions: it informs the initial asset assessment that determines whether enforcement is worth pursuing, and it provides the identification data required by the Federal Bailiff Service to initiate enforcement proceedings against specific assets.

The Federal Bailiff Service operates its own asset search mechanism once an enforcement instrument is lodged. Bailiffs have statutory authority to query a range of state registers — including those where public access is restricted — and to receive responses that a creditor acting independently cannot obtain. This means that the gap created by post-2022 disclosure restrictions is partially — not fully — bridged by the formal enforcement process. The bailiff's query is directed at the specific debtor named in the enforcement instrument; it does not constitute an asset discovery exercise across related or affiliated entities.

Creditors who hold enforcement instruments against a Russian company but suspect that assets have been transferred to affiliates — a common pattern in distressed asset situations — will therefore need to pursue subsidiary claims separately. These may include transactions set aside under Russian insolvency legislation (where the debtor is in or approaching insolvency proceedings), claims for subsidiary liability of controlling persons, or independent tracing claims before Russian state courts. Each of these routes requires that the affiliate relationship be established through evidence, and corporate registry searches are the primary evidentiary starting point for that exercise.

Under Russian insolvency legislation, preferential transfer claims may be brought for transactions completed within defined look-back periods before the bankruptcy filing. A creditor who delays engaging with the registry evidence risks allowing the look-back window to narrow, reducing the universe of transactions that can be challenged. This is not a theoretical concern — it is a live timing issue in any matter involving a Russian debtor in financial difficulty.

Creditors who are assessing whether a transfer to an affiliate is traceable and challengeable under Russian insolvency legislation benefit from early specialist advice. Contact the team at info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The analytical output of a thorough Russian corporate registry search should address five questions before enforcement proceedings are initiated. First: is the debtor entity still active? EGRUL records the status of a legal entity — active, in liquidation, in bankruptcy, or struck off. A creditor pursuing an entity that has been struck off may be pursuing a claim with no effective respondent. Second: has the registered address been updated recently? A series of address changes within a short period is a recognised indicator of asset-stripping activity in Russian practice.

Third: have there been recent changes in directorship or shareholding composition? Rapid personnel changes at the directorship level, or a transfer of participation shares in the period leading up to a creditor demand, merit scrutiny under the look-back provisions available under Russian insolvency and corporate legislation. Fourth: are there existing insolvency proceedings? An EFRSB search will confirm whether bankruptcy proceedings have been initiated and, if so, at what stage. Entry into bankruptcy triggers a stay on individual enforcement actions and requires the creditor to file a proof of claim within the statutory window — a deadline whose consequences are severe for creditors who miss it.

Fifth: are there existing pledge registrations or enforcement actions against the same assets? The notarial pledge register and any available court enforcement information will indicate whether competing creditors have already secured priority over specific assets.

For creditors tracing assets through EAEU-member corporate structures — a common feature of offshore asset Russia arrangements where assets are held through Kazakh, Belarusian, or Armenian entities — registry searches in those jurisdictions must be coordinated with the Russian search. The firm collaborates with trusted local counsel in EAEU and CIS jurisdictions to support cross-border asset identification. This is the correct scope of an asset tracing exercise where the Russian debtor is one node in a wider structure.

The Asset Tracing & Recovery practice at Vetrov & Partners supports foreign creditors across the full asset tracing lifecycle — from initial registry searches through to enforcement proceedings before Russian arbitrazh courts.

For related procedural guidance, see also A practical guide to Russian corporate registry searches and Russian corporate registry searches for asset tracing: further analysis.

• A practical guide to Russian corporate registry searches
• Russian corporate registry searches for asset tracing: further analysis
• Asset Tracing & Recovery: practice overview

Q: What information does an EGRUL search actually return for a Russian limited liability company?

A: An EGRUL extract for a Russian limited liability company discloses the entity's registered name, address, taxpayer identification number, date of registration, general director, and the names and nominal shareholding percentages of participants. It does not disclose passport or identification data of individuals in the public extract (this data has been restricted since 2022), and it does not disclose the shareholder register of joint-stock companies — that document is held by a separate licensed registrar. For asset tracing purposes, EGRUL data is a starting point, not a complete asset map.

Q: Can a foreign creditor access Russian corporate registry data directly, without local counsel?

A: EGRUL data is publicly accessible online without charge. A foreign creditor can, in principle, retrieve a basic extract. However, interpreting the extract — identifying the significance of address changes, cross-referencing participant data with other registries, recognising indicators of asset-stripping activity — requires familiarity with Russian corporate practice. More importantly, the registries where access is restricted (Rosreestr personal ownership data, bailiff asset search outputs) are only accessible through formal legal process. A creditor proceeding without local counsel will reach the boundary of open-source registry access quickly and may draw incorrect conclusions from incomplete data.

Q: How have the 2022 disclosure restrictions affected asset tracing through Russian registries?

A: Amendments to Russian personal data protection legislation and related Federal Tax Service and Rosreestr administrative decisions have removed personal identifying information from standard public extracts in certain registries. The most significant practical effect is on Rosreestr: property registered to individuals now frequently discloses the fact of ownership without disclosing the owner's identity in the public extract. This gap can be filled through formal enforcement proceedings — bailiffs have statutory authority to query restricted registry fields — but this requires that enforcement has already been initiated and an enforcement instrument lodged. The consequence for creditors is that preliminary asset assessment based on open-source registries may understate the true asset position of an individual debtor.

Q: What happens if the Russian debtor company has already entered insolvency proceedings?

A: If EFRSB confirms that bankruptcy proceedings have been initiated against the debtor, individual enforcement actions are stayed under Russian insolvency legislation. The creditor must file a proof of claim within the statutory period, failing which the claim may be excluded from the creditor register or relegated to a lower priority class. The statutory filing window runs from the date of the publication of the bankruptcy notice on EFRSB. Missing this deadline has materially adverse consequences for the creditor's position — the risk is particularly acute for foreign creditors who are not monitoring Russian insolvency publications in the ordinary course of business.

Q: Is there a viable route to tracing assets held through EAEU or CIS holding structures above a Russian debtor?

A: Assets held through entities incorporated in EAEU member states — Kazakhstan, Belarus, Armenia, Kyrgyzstan — or other CIS jurisdictions are not visible in EGRUL. They require separate registry searches in each relevant jurisdiction. The commercial registries of EAEU member states vary significantly in accessibility, the quality of data disclosed, and the availability of formal legal process to compel disclosure. A coordinated multi-jurisdiction search, conducted through local counsel in each relevant state, is the methodologically correct approach. A single-jurisdiction EGRUL search will not detect assets held above the Russian operating entity in a multi-tier structure.

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 and recovery practice advises foreign creditors, institutional investors, and distressed asset buyers on identifying, securing, and enforcing against Russian assets. The practice encompasses corporate registry analysis, cross-border asset identification through EAEU and CIS networks, enforcement proceedings before Russian arbitrazh courts, and creditor-side representation in Russian insolvency proceedings. With over 1,000 matters handled since inception, the team brings direct partner involvement and deep procedural knowledge to every engagement.

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

If you are assessing the recoverability of Russian assets or considering enforcement proceedings against a Russian debtor, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

In practice, the Rosreestr property register is one of the most underused investigative tools available to foreign creditors pursuing enforcement against Russian counterparties. Creditors who arrive in Russia with a debt to recover frequently focus on court proceedings and overlook the informational infrastructure that Russian law places, largely without charge, in the public domain. The Unified State Register of Real Estate — known in Russian practice as the EGRN and administered by Rosreestr — records ownership, encumbrances, mortgages, and historical transfers of all immovable property across the Russian Federation. For a foreign creditor or its Russian legal counsel, systematic interrogation of that register is often the fastest and most cost-effective first step in a recovery strategy involving Russian real estate assets.

The EGRN, maintained by the Federal Service for State Registration, Cadastre and Cartography (Rosreestr), is the authoritative public record for all rights to immovable property in Russia. Under Russian real estate legislation, no right in rem over immovable property — whether ownership, long-term lease, pledge, easement, or servitude — is legally valid until it is registered in the EGRN. This principle of constitutive registration has a practical consequence of direct relevance to foreign creditors: an unregistered transfer of real estate has no legal effect, meaning that a debtor cannot quietly move property out of reach without leaving a legible trace in the register.

The register is structured in layers. The first layer records current ownership — the identity of the registered owner, the cadastral number of the object, its area, address, and category. The second layer records current encumbrances — existing mortgages, court-imposed prohibitions on disposal, arrest orders, and servitudes. The third layer, accessible through extended extracts, records the history of ownership transfers — each registered transaction in sequence, including the dates and, in some cases, the form of acquisition (purchase, gift, contribution to charter capital, inheritance).

What the register does not record is also relevant. Rights arising from unregistered agreements, informal arrangements, nominee structures involving natural persons, and claims that have not yet progressed to a court-ordered prohibition are all invisible to Rosreestr. The register reflects legal title as recognised by the state; it does not capture economic or beneficial ownership in the sense familiar to practitioners in common-law jurisdictions. A creditor relying exclusively on the register without cross-referencing corporate registry data, transaction filings, and court databases will receive an incomplete picture. The register is, however, the indispensable starting point.

For foreign clients who wish to understand the Asset Tracing & Recovery landscape in Russia before committing to enforcement proceedings, a Rosreestr-based analysis typically takes between two and five working days and can be initiated without any court involvement or advance notice to the counterparty.

Access to the EGRN for foreign creditors is broader than many practitioners assume. The register is publicly accessible under Russian information legislation, and extracts can be requested by any individual or legal entity — including foreign entities — through several channels: the Rosreestr online portal, the State Services (Gosuslugi) platform, and in-person submission through Multifunctional Centres (MFCs). In practice, foreign creditors operating through Russian legal counsel will access the register digitally, with counsel's qualified electronic signature enabling authenticated submissions and receipt of legally valid extracts.

The principal document produced by the register is the extract from the EGRN (Выписка из ЕГРН). Several variants are available. The standard ownership extract confirms current registered ownership of a specific object and lists any registered encumbrances. The extended extract, available to owners and — critically — to certain categories of requestors including courts and notaries but also, in specific circumstances, to parties with a demonstrated legal interest, provides the full transfer history. In enforcement practice, the extended extract is the investigatively valuable document: it reveals whether the debtor transferred property in the period prior to insolvency proceedings, which may give rise to avoidance claims or preferential transfer challenges.

A further category of extract — the rights extract (Выписка о правах) — lists all registered immovable property held by a named individual or entity. This is the search instrument most directly useful for asset tracing purposes: provided the creditor has the debtor's full name and, for natural persons, date of birth, or the debtor entity's TIN (INN), the register will produce a list of all property currently registered in that name across the Russian Federation. This is a materially more powerful instrument than equivalent searches in most European jurisdictions, where property registers are organised by object rather than by owner.

State fees for EGRN extracts are modest — typically in the range of several hundred to a few thousand roubles per object or per entity search — and turnaround through the online portal is, for standard extracts, usually within three to five working days.

If you are a foreign creditor seeking to identify Russian real estate assets held by a counterparty — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Reading a Rosreestr extract requires legal analysis, not merely data retrieval. The encumbrance section of an EGRN extract will list any of the following: a registered mortgage (ipoteka) securing a specific debt obligation; a prohibition on disposal imposed by a court, bailiff, or investigative authority; a seizure order (arest) entered in the context of civil or criminal proceedings; a long-term lease registered against the object; or an easement. The practical importance of each category differs.

A registered mortgage confers priority on the mortgagee in any enforcement sale: in Russian insolvency proceedings, secured creditors with registered pledges over immovable property are paid from the proceeds of that asset in priority to the general creditor pool. A foreign creditor who discovers, on reading the extract, that the debtor's principal real estate asset is already subject to a registered mortgage must recalibrate its recovery expectations accordingly — and must assess, among other things, whether that mortgage was registered within the period during which it might be challenged as a preference.

A court-ordered prohibition on disposal or a bailiff's seizure order, by contrast, indicates that enforcement proceedings are already active against the debtor. The presence of multiple overlapping seizure orders from different claimants tells the creditor that it is not alone in pursuing this debtor — and that speed of action is material. Under Russian civil procedure and enforcement legislation, the order of satisfaction among unsecured creditors in enforcement proceedings follows registration sequence and claim priority rules that differ from the absolute priority of English or Dutch insolvency law.

The historical transfer section of an extended extract deserves particular attention in distressed asset situations. Under Russian insolvency legislation, transactions completed by the debtor within the three years preceding the commencement of bankruptcy proceedings may be subject to avoidance if they were made with related parties at below-market value, or within the one-year period for transactions that disadvantaged creditors. A creditor that identifies a transfer of real estate from the debtor to a related party within this window — visible in the ownership history of the extended extract — has a potentially valuable avoidance claim to bring before the insolvency manager or the arbitrazh court.

"The transfer history held in an extended EGRN extract can expose pre-insolvency disposals that the debtor has not disclosed — in our experience, this is among the most consequential intelligence a creditor can acquire before committing to litigation strategy." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

Despite the relative openness of the EGRN, there are access restrictions that foreign creditors must understand. The full transfer history and the owner-based rights extract are not unrestricted public documents in all circumstances. Access to certain categories of extended extract — particularly the rights extract listing all property held by a natural person — requires either the consent of the registered owner, a court order, or the involvement of a notary acting in a specific capacity (for example, in succession proceedings). Bailiffs and insolvency managers, by contrast, have statutory rights to access the full register without restriction.

For a creditor who has not yet initiated proceedings, access to the extended rights extract may therefore require a procedural step — typically, filing an application in court proceedings (whether a debt claim, an application to open bankruptcy proceedings, or an application for interim measures) that gives the court or appointed officer the right to make register enquiries on the creditor's behalf. This is not a barrier to intelligence-gathering; it is a sequencing consideration that must be factored into the enforcement strategy.

Russian data protection legislation has introduced further nuance. Following amendments to personal data rules affecting state information systems, requests concerning natural persons may now require the requestor to specify the legal basis for the enquiry. For foreign creditors this creates a modest procedural layer that Russian counsel will navigate as a matter of routine, but which can cause delay if the request is submitted without adequate documentary grounding.

The practical question for many foreign creditors is not only what Rosreestr contains, but how the data extracted from it can be used in proceedings outside Russia. This arises in two principal contexts: enforcement of a foreign arbitral award in Russia, and asset tracing in support of proceedings before a foreign court or arbitral tribunal.

In the first context — enforcing a foreign award against Russian real estate — the Rosreestr extract establishing the debtor's ownership of the relevant asset is a document that the Russian arbitrazh court will require as part of the enforcement and execution package. Without a current extract confirming that the asset remains in the debtor's name, an application for enforcement against specific real estate cannot proceed. A creditor who obtains a favourable exequatur order from the Russian court but then finds that the asset has been transferred must either initiate a transfer-challenge claim or redirect enforcement efforts. The register is the instrument that prevents this outcome — or at least identifies it before enforcement costs are committed.

In the second context — using Russian register data in foreign proceedings — Rosreestr extracts are official documents of a Russian state authority and, where apostilled, are recognised as authentic public documents in signatory jurisdictions under the Hague Convention. A creditor conducting worldwide asset-tracing litigation in London, Amsterdam, or Paris may use apostilled EGRN extracts as evidence of Russian property holdings, subject to the evidentiary rules of the relevant foreign court. The apostille process for EGRN extracts is handled through the Russian Ministry of Justice and adds approximately ten to fifteen working days to the timeline.

The Restructuring & Insolvency dimension also intersects here: where a debtor has filed for insolvency in Russia while simultaneously holding assets in multiple jurisdictions, the Rosreestr extract establishing the Russian asset inventory is a material document for foreign insolvency recognition proceedings and for coordinated multi-jurisdictional recovery strategy. Our Matters section includes examples of cross-border creditor mandates where register analysis formed the foundation of the recovery framework.

Creditors who delay commissioning the register analysis risk the possibility that the debtor — or a connected party on its behalf — will take steps within the window before proceedings are filed. Under Russian civil procedure, a registered disposal that has completed before a court prohibition is entered is difficult to reverse without a successful avoidance claim. The register's constitutive principle works both ways: it protects a creditor who moves quickly, and it protects a transferee who acts before a prohibition is registered.

If you are instructing Russian legal counsel in connection with enforcement or asset recovery proceedings — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For a foreign creditor or its legal advisers, commissioning a systematic Rosreestr-based investigation involves several discrete steps, each of which produces intelligence that informs the next.

The first step is identifier collection. A creditor must have, at minimum, the debtor's TIN (INN) for a legal entity, or full name and date of birth for a natural person. These identifiers are obtainable from the corporate registry (for legal entities), from contractual documentation, or from prior correspondence. Without accurate identifiers, the rights extract by owner cannot be generated reliably — a search by name alone may produce false negatives or incomplete results.

The second step is the ownership search. Using the rights extract, counsel will identify all immovable property currently registered in the debtor's name across all Russian regions. The extract lists each object by cadastral number, type (land plot, building, residential or non-residential premises, unfinished construction object), location, and the date on which the right was registered. This step produces the asset inventory — the map of what exists to enforce against.

The third step is the object-level encumbrance check. For each asset identified in the ownership search, counsel requests a standard object extract confirming current encumbrances. This step establishes which assets are already mortgaged (and to whom), which are subject to court orders or seizures (and in whose favour), and which are unencumbered and therefore available for enforcement.

The fourth step, where the ownership or encumbrance position is legally significant, is the extended transfer history extract. For assets acquired by the debtor shortly before the apparent onset of financial difficulty, or transferred away from the debtor in the preceding three years, the transfer history establishes the factual basis for an avoidance claim or for a deeper investigation into beneficial ownership through corporate vehicles.

The fifth and final step is cross-referencing the register data against other publicly available sources: the Fedresurs insolvency notifications database, the commercial court proceedings database (Kad.arbitr.ru), the enforcement proceedings database of the Federal Bailiff Service, and, where relevant, the corporate registry filings at the Federal Tax Service. The register does not exist in isolation; its investigative value is maximised when its data is read alongside these parallel sources, each of which reveals a different dimension of the debtor's legal position and asset profile.

The Ministry of Finance guidance on Rosreestr and the related practitioner briefing on the register as an investigative instrument provide supplementary detail on specific procedural updates and Ministry-level interpretations that affect how requests should be framed and what documentation supports access.

A complete Rosreestr-based asset intelligence report of this kind typically takes five to ten working days with instructed Russian counsel, and in the firm's experience can be completed without any requirement for the debtor's knowledge or cooperation. The intelligence produced at this stage is the foundation for all subsequent enforcement decisions — including whether to file for execution directly, whether to apply for interim measures, whether to support or contest insolvency proceedings, or whether to negotiate from a position of accurate knowledge of what assets exist.

To discuss commissioning an asset intelligence report for a Russian counterparty — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What exactly does a Rosreestr extract show, and is it available in English?

A: A standard EGRN extract confirms current registered ownership of a specific immovable property, the identity of the owner, the cadastral number, the property's characteristics, and any registered encumbrances — including mortgages, court-ordered prohibitions, and seizures. Extended extracts additionally show the historical sequence of ownership transfers. Extracts are issued in Russian only; foreign creditors operating through Russian legal counsel will commission certified translations for use in foreign proceedings. An apostille can be obtained through the Russian Ministry of Justice if the extract is to be used as evidence before a foreign court. The extract itself is an official document of a state authority and carries the force of an authentic public record under Russian administrative law.

Q: Can a foreign creditor search Rosreestr directly, without appointing Russian counsel?

A: In principle, any person or entity — including a foreign legal entity — may submit a request to the Rosreestr online portal. In practice, foreign creditors without a Russian legal presence will face difficulties with the authentication requirements of the portal, which requires a qualified electronic signature issued by a Russian-accredited certification authority, or submission through a Russian notary. The rights extract by owner — the most valuable instrument for asset tracing purposes — has additional access conditions that typically require either the owner's consent, a court-linked basis, or counsel who can establish and document the legal interest of the requestor. Appointing Russian counsel eliminates these procedural barriers and ensures that the resulting extract is correctly obtained, legally valid, and immediately actionable.

Q: How current is the information in the register — could assets have been transferred before a search is completed?

A: The EGRN reflects the current registered position as of the date of the extract. A transfer or encumbrance that completes registration after the extract is issued will not appear in that extract. The registration of a transfer of immovable property in Russia takes, under the standard procedure, between five and ten working days from submission of the transaction documents to Rosreestr. This window means that a creditor who identifies an asset and moves quickly — by applying for an interim court order prohibiting disposal, which is registered against the object immediately upon the court's decision — can secure the asset before a transfer completes. The practical priority, for creditors who have identified Russian real estate assets, is therefore to apply for interim measures without delay. Once a prohibition is registered by the court, any subsequent transfer application will be rejected by Rosreestr until the prohibition is lifted.

Q: Are transfers of Russian real estate that took place before our debt arose also visible in the register?

A: The extended extract provides the transfer history from the time the object was first entered into the EGRN — which covers the period since the unified register was established and, for many objects, extends back to the late 1990s or early 2000s. Transfers predating the EGRN may be visible in archived records but are less consistently accessible. For creditors investigating pre-debt transfers — for example, in the context of a fraudulent conveyance analysis — the transfer history available through the extended extract will typically cover the legally relevant lookback periods under Russian insolvency legislation (three years for related-party transactions; one year for transactions disadvantaging creditors). Earlier transfers are of limited legal relevance under the available avoidance mechanisms, though they may be relevant to demonstrating a pattern of conduct.

Q: What happens if the debtor holds Russian real estate through a corporate vehicle rather than directly?

A: This is the most common structural obstacle in Russian asset-tracing work. Where the debtor holds real estate through a wholly owned or controlled Russian legal entity, the EGRN extract will show the entity — not the debtor — as the registered owner. The investigation must then extend to the corporate layer: identifying ownership and control of the holding entity through the corporate registry, examining whether the entity itself has debts or insolvency exposure, and assessing whether the interposition of the corporate vehicle constitutes an improper transfer that could be unwound. Russian courts have, in a number of insolvency and enforcement matters, permitted the disregard of corporate form where the holding structure was established with the specific intent of placing assets beyond the reach of creditors — but this is a complex, fact-intensive analysis that carries no guarantee of success. The firm's Asset Tracing & Recovery practice routinely advises on multi-layer holding structures of this kind.

• Ministry of Finance issues guidance on Rosreestr
• Rosreestr property register as an investigative instrument — practitioner briefing
• Asset Tracing & Recovery — practice overview

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 cross-border litigants on identifying, preserving, and enforcing against Russian-registered assets. Mandates range from preliminary register-based asset intelligence through to full enforcement proceedings in the Russian arbitrazh courts, with coordination of foreign proceedings where multiple jurisdictions are involved. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

When a foreign creditor holds a Russian judgment or arbitral award and turns to enforcement, the most common obstacle is not the existence of assets – it is finding them. Russian debtors operate across a layered banking architecture, and bank account information is not publicly accessible in the way that real property registers or corporate filings might be. Tracing bank accounts and financial flows in Russia is therefore a distinct legal and procedural exercise, governed by a body of rules that intersects civil procedure, tax administration, banking regulation, and – in insolvency settings – the specialist provisions of Russian bankruptcy legislation. For foreign creditors unfamiliar with the Russian legal framework, the gap between holding an enforceable title and actually identifying where a debtor keeps its money is the gap that defeats recovery.

Asset tracing in the Russian context is not a single procedure – it is a sequence of overlapping mechanisms, each governed by different rules and administered by different authorities. Foreign creditors and their advisers should understand the distinction at the outset.

The first level is identification: establishing at which banks a debtor holds accounts, and in what currency. Russian banking secrecy rules – grounded in the Federal Law on Banks and Banking Activity – impose strict confidentiality obligations on credit institutions. A bank will not disclose account details to a private creditor on demand, regardless of whether that creditor holds a court judgment. This confidentiality is not absolute, but the exceptions are procedurally specific and require the creditor to work through formal channels rather than directly.

The second level is disclosure: obtaining an order or administrative direction that compels a bank or the Federal Tax Service to provide account information to the appropriate enforcement body. Russian civil procedure provides tools for this at the enforcement stage, but the access point for a foreign creditor is typically the Federal Bailiff Service (FSSP), which holds powers to query banks directly under the enforcement legislation.

The third level is freezing: once accounts are identified, applying interim relief or directing the bailiff to arrest funds. Russian asset freeze mechanisms under civil procedure permit pre-judgment interim measures in some circumstances, but in practice the more reliable route is the post-judgment enforcement path through the FSSP.

The fourth level is tracing financial flows: reconstructing where money has moved, to whom, and whether those movements can be challenged – for example, as preferential or fraudulent transfers under Russian insolvency legislation. This fourth level is qualitatively different from the first three. It requires analysis of bank statements, corporate transaction records, and in insolvency proceedings, cooperation of the bankruptcy trustee. It is where asset tracing and recovery overlap most directly.

Understanding which level is relevant to a given matter determines which Russian legal tools apply, which authorities are involved, and what timelines are realistic.

If you are a foreign creditor at any of these stages – identification, freeze, or recovery of transferred funds – make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The Russian legal framework for financial disclosure does not give private creditors direct access to banking information. Access is mediated through state bodies, and the creditor's role is to activate those bodies through the correct procedural channels.

The Federal Bailiff Service is the central instrument. Once a creditor has obtained a writ of execution – issued by the court following entry of a judgment or recognition of an arbitral award – the bailiff is empowered to send enquiries directly to Russian credit institutions asking for confirmation of account existence and balance. The bank is legally obliged to respond within three working days. This is the most direct statutory route for account identification, and it is routinely used in enforcement proceedings before Russian arbitrazh courts and courts of general jurisdiction.

The Federal Tax Service holds a separate, parallel database of taxpayer bank accounts. Every Russian legal entity and sole trader is required to notify the FTS of new bank accounts within defined periods. The FTS database is not publicly accessible, but it is accessible to enforcement authorities – including the FSSP and, in insolvency proceedings, the bankruptcy trustee. For foreign creditors pursuing enforcement via a Russian court-appointed mechanism, access to the FTS account register through the trustee or the FSSP is a significant practical tool.

Russian civil procedure also allows a court, at the request of a party, to request information from a bank or financial institution as part of securing evidence or giving effect to interim relief. Pre-judgment interim measures in Russian civil and arbitrazh procedure can include the arrest of funds in identified accounts. The challenge is that pre-judgment measures require the creditor to identify the account first – a circularity that makes pre-judgment financial tracing procedurally demanding. Courts have discretion to grant interim orders on the basis of a credible showing of account existence, and where a creditor can demonstrate prior payment history (for example, through prior invoices or bank transfer confirmations), this can be sufficient to support an application.

In insolvency proceedings – the restructuring or liquidation of a Russian entity under Russian insolvency legislation – the bankruptcy trustee has the most extensive access of any party. The trustee is entitled to obtain bank statements for any account held by the debtor for the three-year period preceding the filing date, to demand information from counterparties, and to apply to the court for disclosure orders against third parties who may hold debtor assets. For foreign creditors who are admitted as creditors in Russian insolvency proceedings, the trustee's powers are in effect shared powers – but only if the creditor is actively engaged in the proceedings and able to direct the trustee's investigative efforts.

The framework is therefore not deficient in scope. What it demands is procedural engagement: the creditor must be properly positioned within the Russian enforcement or insolvency mechanism before the tools become accessible.

The enforcement of financial disclosure orders in Russian proceedings operates through two parallel tracks: the FSSP track for civil execution, and the court's own supervisory jurisdiction within insolvency and corporate dispute proceedings.

Under the civil execution track, the bailiff issues a demand to the bank. The bank's obligation is mandatory, and failure to comply carries administrative and, in egregious cases, criminal liability for responsible bank officers. In practice, major Russian banks respond promptly. The challenge for foreign creditors arises not from bank non-compliance but from debtor-side structuring: accounts held in the name of affiliated entities, accounts recently opened and emptied, or payments routed through intermediaries to avoid the debtor's own accounts appearing in the FSSP query.

Russian courts have developed a body of practice around these evasion patterns. Where a debtor is shown to have transferred funds to a related party in the period preceding enforcement, Russian insolvency legislation provides for a challenge to that transfer as a preferential or fraudulent transaction. The time window for such challenges extends up to three years before the insolvency filing date – a window that foreign creditors who arrive late to enforcement proceedings routinely underestimate. Early action, before the debtor initiates insolvency voluntarily, is therefore critical to preserving the creditor's ability to trace and recover transferred funds.

Interim asset freeze applications in Russian arbitrazh proceedings – the courts that handle commercial disputes – follow a notice procedure, but Russian courts will in some cases grant ex parte interim relief where there is a demonstrated risk of dissipation. The standard is not identical to the English Mareva jurisdiction, and Russian courts apply their own criteria, but the underlying policy concern – preventing a debtor from moving assets to defeat enforcement – is the same. Demonstrating a risk of dissipation typically requires showing specific debtor conduct: recent unexplained asset transfers, acceleration of payments to affiliates, or documented evidence of account closure.

"The most consistent finding in our asset tracing work is that Russian courts are well equipped to order financial disclosure – the constraint is almost always procedural positioning, not the absence of legal tools." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

Court-ordered disclosure within arbitrazh proceedings can extend to third-party banks and counterparties. Where a creditor can demonstrate that debtor funds passed through a specific third-party account, an application for disclosure from that third party is procedurally available, though courts apply it selectively and will require a factual foundation for the application.

For creditors considering interim measures or disclosure applications in Russian arbitrazh proceedings – speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Not all foreign creditors are equally positioned to access Russian financial tracing mechanisms. The effectiveness of each tool depends on the creditor's procedural status and the stage of the debtor's legal situation.

Foreign trade creditors holding a Russian court judgment are the most directly placed. With a writ of execution in hand, the FSSP pathway is immediately available. The practical challenge is the enforcement stage gap: from the date of the final judgment to the issuance of the writ and the first FSSP query, several weeks may pass. Debtors who anticipate enforcement use this window. Foreign creditors who have been tracking the debtor's conduct during litigation and who are prepared to apply immediately for the writ and instruct the FSSP from day one of enforcement are materially better positioned than those who treat the judgment as the end of the process.

Foreign creditors holding a recognised foreign arbitral award face an additional step: recognition and enforcement through a Russian arbitrazh court under the New York Convention framework. Once the recognition order is obtained, the enforcement pathway is identical to that available to domestic judgment creditors. The recognition stage is not merely procedural – it is the point at which Russian courts may examine grounds for refusal, and it requires careful preparation of the application. The time between filing for recognition and obtaining the order, in contested cases, can extend to several months, during which the debtor's asset profile may change materially.

Institutional creditors – banks, bondholders, or fund creditors with exposure to Russian entities – often encounter tracing issues in the context of distressed assets and pending or threatened insolvency. For these creditors, the most valuable tools are not the FSSP pathway but the insolvency-adjacent tools: participation in creditor committees, engagement with the bankruptcy trustee, and applications to court for disclosure within the insolvency proceedings. The insolvency track offers broader investigative reach than civil execution, at the cost of sharing recovery across the creditor body. The strategic choice between pursuing civil execution aggressively and allowing or participating in insolvency is one of the most consequential decisions a foreign creditor in Russia faces – and it is time-sensitive.

For EAEU-based creditors – entities from Kazakhstan, Belarus, Armenia, or Kyrgyzstan – the mutual enforcement framework within the EAEU offers a somewhat simplified recognition pathway for court judgments, which reduces the front-end delay before the FSSP pathway opens. CIS treaty mechanisms operate similarly for judgments from CIS member states. These pathways do not alter the substance of the tracing tools available, but they reduce the time window during which a debtor can anticipate enforcement and act accordingly.

Creditors who delay initiating enforcement proceedings risk losing priority in an insolvency that may be filed unilaterally by the debtor – and, critically, losing the three-year lookback window for challenging preferential transfers that were completed before the limitation period calcified.

The following sequence reflects the approach taken in asset tracing matters handled by the firm across the Siberian and Ural federal districts, and in arbitrazh proceedings before Russian commercial courts.

The first step is jurisdictional mapping. Before any enforcement or tracing action, a creditor needs to confirm: which Russian courts have territorial jurisdiction over the debtor entity; whether the debtor holds assets in Russia directly or through affiliates; whether insolvency has been filed or is likely; and which enforcement authority – FSSP or insolvency trustee – is the relevant actor. This mapping exercise directly determines which tools are available and in which sequence they should be deployed.

The second step is evidence preservation. Available open-source information about the debtor's banking relationships – payment details on prior invoices, account numbers used in prior transactions, correspondent bank details on wire transfers – should be gathered and organised before formal proceedings begin. Russian courts and the FSSP will move more efficiently when a creditor can demonstrate a specific bank or account as the starting point for enquiry, rather than requesting a general sweep.

The third step is the enforcement application. For creditors with a judgment or recognised award, this means instructing Russian counsel to prepare the FSSP application promptly, designating the relevant territorial bailiff's office, and – where there is evidence of imminent dissipation – filing simultaneously for interim measures in the arbitrazh court. The two applications are complementary, not mutually exclusive.

The fourth step is active monitoring of the FSSP process. Russian enforcement proceedings require active creditor participation. Bailiff offices operate under caseload pressure, and matters where the creditor is represented by Russian counsel who engage regularly with the bailiff – submitting updated debtor information, identifying new assets as they come to light, escalating stalled proceedings – produce materially better outcomes than matters where the creditor files and waits.

The fifth step, in cases where funds have been moved, is the transfer challenge. Under Russian insolvency legislation, preferential and fraudulent transfer claims are brought as separate applications within the insolvency proceedings. The grounds, the evidentiary standard, and the available remedies differ depending on the type of transfer and the period in which it occurred. Local Russian counsel with experience of the insolvency courts in the relevant federal district is essential for this step – procedural practice in the Siberian and Ural circuits has its own specific contours that differ from Moscow-centric guidance.

For matters involving Asset Tracing & Recovery across multiple jurisdictions or where the debtor group extends beyond Russia, coordination between Russian enforcement proceedings and foreign-jurisdictional steps – asset freeze applications in third countries, correspondent bank tracing, or recognition of Russian insolvency orders abroad – is managed in consultation with the firm's network of international counsel. Related analysis of Russian Supreme Court clarification on tracing methodology is set out in Russian Supreme Court clarification on tracing bank accounts, and a procedural guide to navigating the process in practice is available at Navigating the tracing of bank accounts and financial flows in Russia.

Creditors with exposure to distressed assets in Russian law contexts should also review the Restructuring & Insolvency practice area, which covers the insolvency-side tools available in parallel to civil enforcement. A representative selection of the firm's recovery-side matters is available at /matters/.

If you are a foreign creditor with an enforcement or tracing matter in Russia – request our practice review: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Russian Supreme Court clarification on tracing bank accounts
• Navigating tracing of bank accounts and financial flows in Russia
• Asset Tracing & Recovery — practice overview

Q: Can a foreign creditor access Russian bank account information directly, without going through a Russian court or bailiff?

A: No. Russian banking secrecy legislation prohibits credit institutions from disclosing account information to private parties, including foreign creditors holding enforceable titles. Access to bank account data is available only through state enforcement bodies – principally the Federal Bailiff Service and, in insolvency proceedings, the bankruptcy trustee. A foreign creditor must therefore be engaged in active Russian enforcement proceedings before account identification tools become available. There is no equivalent of a direct banker's order or third-party disclosure application that operates outside the state enforcement mechanism.

Q: What is the time limit for challenging a debtor's transfer of funds before a Russian insolvency filing?

A: Under Russian insolvency legislation, preferential transfer claims can be brought in respect of transactions completed within a defined period before the bankruptcy filing date. For transfers to related parties or transactions where the debtor received inadequate consideration, the relevant window extends up to three years before filing. Ordinary preferential transfers – those made to unrelated third parties on arms-length terms but which preferred one creditor over others – attract a shorter period. These limitations are calculated from the date the insolvency application is accepted by the court, not from the date the creditor became aware of the transfer. Foreign creditors who delay engagement with Russian proceedings may find that the limitation window has closed on significant transfers.

Q: Does Russian civil procedure allow pre-judgment asset freezing for foreign creditors?

A: Russian civil procedure – specifically the arbitrazh procedural rules applicable to commercial disputes – does permit pre-judgment interim measures, including the arrest of funds in specific bank accounts. A foreign creditor may apply for such measures before or simultaneously with the filing of a claim. The court will require a showing of: (i) the existence of a claimable right or obligation; (ii) a risk that enforcement will be frustrated if measures are not granted; and (iii) proportionality between the measures requested and the claim value. Courts have granted such orders on the basis of documented prior payments from an identified debtor account, combined with evidence of recent unexplained fund movements. The standard is demanding, but not insurmountable with properly prepared evidence.

Q: How long does FSSP-administered bank account tracing typically take in practice?

A: Once a writ of execution is presented to the relevant territorial FSSP office and enforcement proceedings are formally opened, the bailiff is required to send account enquiries to identified banks within a matter of days. Bank responses are due within three working days of receipt of the enquiry. In practice, the full cycle from writ presentation to first confirmed account identification – where accounts exist at the queried banks – is measured in weeks rather than months, provided the creditor has identified the correct FSSP office and engaged Russian counsel to maintain active contact with the bailiff. Where initial enquiries return negative results and broader bank searches are needed, timelines extend. Active creditor-side engagement is the single most significant variable in the speed of this process.

Q: If a debtor has transferred funds abroad, can Russian enforcement proceedings assist in tracing those flows?

A: Russian enforcement and insolvency proceedings provide tools for identifying domestic flows – transfers between Russian accounts and payments to Russian counterparties. For funds transferred abroad, Russian proceedings can establish the fact of the outbound transfer through bank statement disclosure, but recovery of those funds requires parallel action in the destination jurisdiction. Russian insolvency orders are not automatically recognised abroad, and tracing actions against foreign-held assets must be initiated through the courts or enforcement bodies of the relevant jurisdiction. The firm coordinates cross-border asset tracing matters with trusted local counsel in the destination jurisdiction. Creditors should treat a Russian tracing exercise as one component of a broader recovery strategy, not a self-contained mechanism for recovering assets that have left Russia.

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 and recovery practice advises foreign trade creditors, institutional investors, and foreign law firms acting as instructing counsel on all stages of Russian enforcement: from account identification through the Federal Bailiff Service, to interim asset freeze applications before the arbitrazh courts, to preferential transfer challenges within Russian insolvency proceedings. With over 1,000 matters handled since inception, the team applies direct partner-level involvement to every engagement and maintains active relationships with the Siberian and Ural federal circuit courts and FSSP territorial offices.

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/

In the past several years of advising foreign creditors on Russian asset-tracing matters, one structural pattern recurs with particular frequency: assets that a debtor has transferred into a chain of shell companies, one or more of which has a Russian legal presence, a Russian-registered holding, or a Russian counterparty through which value flows. The question those creditors consistently confront is not merely whether Russian law permits the unwinding of such structures — it does, in limited and condition-dependent ways — but whether the procedural path through Russian courts is compatible with the enforcement mechanisms available to them at home, and whether international legal standards offer any supplementary traction. This analysis examines the Russian legal framework for unwinding shell company arrangements, compares it with the approach taken in leading international jurisdictions, and sets out what foreign creditors need to understand before committing resources to a recovery strategy.

The concept of unwinding a shell company structure — reversing transactions by which assets were moved through nominees, single-purpose vehicles, or purpose-built corporate chains — has no single statutory expression in Russian law. It operates instead through a convergence of several doctrines, each with its own evidentiary standard, forum, and remedial scope.

The primary instrument is the transaction challenge mechanism available in Russian insolvency proceedings. Where a debtor is subject to a Russian bankruptcy procedure, the insolvency administrator — or a creditor with standing — may challenge transactions entered into within defined look-back periods: up to one year for transactions at undervalue, up to three years for transactions made with the intent to harm creditors. This three-year window is materially wider than equivalent provisions in many European jurisdictions, but it is also strictly conditional: the challenging party must demonstrate both that the transaction was commercially unreasonable and that the counterparty was aware of, or ought to have been aware of, the debtor's intent. For shell company arrangements, this awareness standard is often the decisive battleground.

Outside formal insolvency, Russian civil law provides for the recognition of transactions as sham (притворные) or fictitious (мнимые) — categories under the Civil Code that render a transaction void regardless of its formal structure if it was entered into to conceal a different legal relationship or with no intention of creating legal consequences at all. These provisions have been applied by Russian courts to unwinding challenges involving nominee shareholders and shell holding companies with no substantive business activity, though the case-by-case evidentiary burden is substantial.

The third route — increasingly relevant in disputes involving foreign beneficiaries — is the piercing of the corporate veil through attribution of liability to a controlling shareholder or beneficial owner. Russian courts have moved, over the past decade, from a formalistic position that corporate personality is inviolable towards a more functional analysis: where a corporate structure was established and operated not for legitimate commercial purposes but to insulate an individual from liability or to transfer assets beyond creditor reach, courts have been willing to attribute the obligations of the shell entity to the person who genuinely controlled it. This development tracks, though it does not formally replicate, the equitable veil-piercing doctrines familiar to English and Delaware-law practitioners.

If you are a foreign creditor assessing whether assets held through a Russian-connected shell structure are recoverable — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For a foreign creditor seeking to use any of the above instruments, the procedural and evidentiary requirements in Russia differ meaningfully from the documentary standards of common-law asset-tracing practice.

Under the insolvency challenge route, standing is the first threshold. A foreign trade creditor who has obtained an arbitral award or a foreign court judgment must first have that decision recognised by a Russian arbitrazh court before it can be enrolled as a creditor in Russian insolvency proceedings. Recognition of a foreign arbitral award under the 1958 New York Convention is, in principle, available — but Russian courts have applied a materially restrictive interpretation of the public-policy defence in disputes with a cross-border enforcement character, and the timeline from filing to recognition commonly extends to six to nine months even in uncontested cases. A foreign creditor who delays initiating proceedings risks losing priority in an insolvency that may be filed unilaterally by the debtor or by a domestic creditor seeking to control the process. Under Russian insolvency legislation, preferential transfer claims may be brought for transactions completed up to three years before the bankruptcy filing — a window that creditors unfamiliar with Russian law frequently underestimate, but one that can only be accessed by a creditor who has enrolled in time.

The evidentiary standard for establishing that a shell company was used to harm creditors requires the applicant to demonstrate, typically through documentary and forensic accounting evidence, that: (i) the counterparty had no genuine economic rationale for the transaction; (ii) consideration paid, if any, was not equivalent to fair market value; and (iii) the transfer materially reduced the assets available to satisfy creditor claims. Russian courts have accepted expert evidence, comparative market valuations, and corporate registry extracts from foreign jurisdictions as admissible in this analysis — but the burden of production rests with the challenging party, and courts rarely exercise inquisitorial powers to compel disclosure from third parties in the absence of a secured injunction.

On the veil-piercing route, the evidentiary picture is somewhat more flexible. Russian courts examining claims against a controlling shareholder or ultimate beneficial owner have looked to patterns of corporate conduct — the absence of independent management, the direction of funds for personal use, the systematic stripping of assets from the operating entity — rather than requiring proof of a specific intent to defraud in relation to each transaction. This is closer to the English approach of examining the overall character of the conduct than to the more demanding Delaware standard of intentional sham. However, Russian courts apply this doctrine cautiously and have declined to extend it to cases where the corporate structure, however tax-efficient, reflected a genuine business arrangement.

"The critical distinction Russian courts draw is not between onshore and offshore — it is between structures that have substantive economic content and those that are demonstrably empty of it. For foreign creditors, that distinction determines whether litigation is viable." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement & Asset Tracing, Vetrov & Partners

The divergence between Russian and international practice in this area is partly doctrinal and partly procedural — and for foreign creditors, both dimensions matter.

At the doctrinal level, the principal difference between the Russian approach and that of the leading common-law jurisdictions is the degree to which the unwinding remedy is tied to formal insolvency proceedings. In England and Wales, a liquidator's power to challenge transactions at undervalue or preferences operates within the insolvency framework — as in Russia — but English courts have a broader supervisory jurisdiction to grant Norwich Pharmacal orders, worldwide freezing injunctions, and disclosure orders against third parties (including foreign nominees) that operate independently of, and often in anticipation of, formal insolvency. Russian courts have no directly analogous pre-litigation discovery mechanism; the closest instrument is an interim asset freeze (обеспечительные меры), which is available in arbitrazh proceedings but is typically narrower in scope and more difficult to obtain against foreign respondents.

German and Dutch courts — jurisdictions frequently relevant because of the prevalence of Dutch and German holding structures in Russian-connected arrangements — operate under civil-law frameworks that, like Russia's, rely principally on statutory grounds for transaction avoidance. The German Insolvenzordnung and the Dutch Faillissementswet each contain provisions for unwinding preferential and undervalue transactions, broadly comparable in their look-back periods and intent requirements to the Russian equivalents. The key practical difference is that within the European Union, recognition and enforcement of insolvency measures operates under a substantially streamlined regime, reducing the jurisdictional gap that foreign creditors face when an asset is split across a Russian entity and a European holding vehicle.

EAEU member states — Kazakhstan, Belarus, Armenia, Kyrgyzstan — present a separate consideration. Within the EAEU framework, there are developing mutual recognition norms for civil judgments, though the enforcement of Russian insolvency measures across EAEU borders remains subject to bilateral treaty provisions and, in practice, requires separate domestic proceedings in the relevant member state. For creditors dealing with structures that route assets through an Astana or Minsk holding entity before reaching a Russian operating company, this adds a further jurisdictional layer that the purely Russian analysis does not capture.

At the procedural level, the most material international contrast for foreign creditors is the availability — or absence — of pre-action disclosure. Where an English court can order a bank or corporate service provider to disclose beneficial ownership information as part of an asset-tracing action, Russian procedural law provides no equivalent pre-litigation mechanism. A foreign creditor entering Russian proceedings without a pre-formed evidentiary picture of the shell structure will find that the Russian process offers limited assistance in building one. This asymmetry makes thorough offshore investigation — using whatever tools are available in the jurisdictions where the nominee companies are registered — a necessary precondition for a viable Russian enforcement strategy.

If your recovery strategy requires coordinated enforcement across Russian and foreign jurisdictions — speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The complexity of any unwinding strategy increases substantially when the shell company arrangement spans multiple jurisdictions — as most such arrangements do. A typical structure encountered in practice might involve a Russian operating company owned by a Cyprus or BVI special-purpose vehicle, held ultimately by a beneficial owner whose personal assets are held through a UAE or Swiss family office structure. Each jurisdictional layer adds a separate legal system, a separate limitation period, and a separate procedural forum to the creditor's analysis.

For foreign creditors, the implications of this layering are threefold. First, the choice of primary jurisdiction — where to mount the principal challenge — is itself a strategic decision with material consequences for evidence, timing, and enforceability of any order obtained. Initiating in Russia provides direct access to Russian-law remedies against the operating company and any Russian-registered entities in the chain, but leaves assets held by the foreign holding entities outside direct reach unless a separate recognition or enforcement action is pursued abroad. Initiating in England, Germany, or the Netherlands provides access to broader pre-action disclosure tools and, within the EU, smoother recognition of any judgment obtained — but the resulting order will need to be separately enforced in Russia, which may require re-litigating jurisdictional and merits questions before a Russian court.

Second, the beneficial ownership question is almost always central and almost always contested. Russian law imposes disclosure obligations on corporate entities in relation to beneficial owners — maintaining an internal register and, in defined circumstances, filing disclosures with state authorities — but these obligations are observed imperfectly in practice, and nominee arrangements registered in offshore jurisdictions are not subject to Russian disclosure requirements at all. The evidentiary pathway to the ultimate beneficial owner therefore typically runs through non-Russian records: corporate registry extracts, bank disclosure obtained under foreign court orders, and open-source intelligence. The firm regularly collaborates with trusted counsel in the jurisdictions where such tools are available to construct the evidentiary foundation before Russian proceedings are commenced.

Third, the EAEU dimension noted in § III creates a specific risk for creditors who assume that a judgment or insolvency measure obtained in Russia will automatically reach assets held in Kazakhstan or Belarus. It will not. Mutual recognition provisions within the EAEU have been extended incrementally, but asset-specific enforcement — particularly against a shell company registered in a EAEU member state — requires separate domestic proceedings. Creditors should obtain early-stage advice on the EAEU dimension of any structure before committing to a Russia-first strategy.

For related analysis on the legislative context for these proceedings, see Recent legislative amendments affecting unwinding of shell company structures in Russia and our overview at Unwinding shell company structures with Russian elements: a practitioner overview.

The single most consequential factor in the outcome of an unwinding action in Russia is the quality and completeness of the evidentiary picture assembled before Russian proceedings are commenced. Courts examining shell company arrangements do not assist creditors in building their case; the burden of demonstrating the artificial character of the structure, the absence of genuine economic substance, and the causal link between the transactions challenged and the reduction of recoverable assets rests entirely with the applicant.

The practical preparation for a viable Russian unwinding action therefore involves, at minimum: an offshore corporate investigation to map the full structure and identify the beneficial ownership layer; a financial forensic analysis of the transactions by which assets moved through or out of the Russian operating entity; an assessment of the look-back period available under Russian insolvency law relative to the dates of the relevant transactions; and an early-stage application for interim freezing relief if there is reason to believe that further dissipation is ongoing.

Procedural choices made at the outset — including the forum for primary proceedings, the decision whether to seek an interim freeze in Russia or abroad, and the strategy for enrolling in Russian insolvency proceedings if they are already underway — are not easily reversed once made. The Asset Tracing & Recovery practice at Vetrov & Partners advises on the full strategy from initial triage to final enforcement, including coordination with external counsel in the offshore jurisdictions relevant to the structure.

For reference on the Matters Hub, cases of this nature — foreign creditor-side enforcement against Russian-connected shell structures — are documented at /matters/ with illustrative outcomes.

If you are a foreign creditor with assets at risk in a Russian-connected shell structure, an initial 30-minute meeting is complimentary — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Recent legislative amendments affecting unwinding of shell company structures in Russia
• Unwinding shell company structures with Russian elements: a practitioner overview
• Asset Tracing & Recovery: practice overview

Q: What legal mechanism do Russian courts use to look through a shell company to the underlying assets?

A: Russian courts deploy three principal mechanisms: transaction challenge under Russian insolvency legislation (available for transactions made up to three years before a bankruptcy filing, where the intent to harm creditors can be established); the voidance of sham or fictitious transactions under Russian civil law (applicable where a transaction had no genuine commercial purpose or concealed a different legal relationship); and veil-piercing through attribution of liability to a controlling shareholder or beneficial owner (available where the corporate structure was demonstrably operated to insulate an individual from liability rather than for legitimate commercial purposes). The appropriate mechanism depends on whether formal insolvency proceedings are under way, the timeline of the relevant transactions, and the nature of the evidence available to the creditor.

Q: Can a foreign creditor initiate unwinding proceedings in Russia without a pre-existing Russian court judgment?

A: Not directly in the form of a transaction challenge within insolvency proceedings — those require the creditor to have enrolled in the Russian bankruptcy process, which itself requires either a Russian-law debt instrument or a recognised foreign judgment or arbitral award. However, a foreign creditor may apply to a Russian arbitrazh court for recognition of a foreign arbitral award or foreign court judgment and, once enrolled, may participate in the insolvency challenge process. Outside insolvency, a foreign creditor with a direct contractual claim governed by Russian law may bring civil proceedings in Russia independently. The recognition step is therefore often the critical threshold: it takes time, and the clock on look-back periods runs regardless.

Q: How long does an asset-tracing and unwinding action typically take in Russian proceedings?

A: The timeline varies substantially depending on whether formal insolvency proceedings are already under way or must be triggered, the complexity of the corporate structure, and whether interim freezing relief is sought. In practice, from instruction to a substantive first-instance decision on a transaction challenge, timelines commonly extend to 18–30 months in contested matters. Insolvency proceedings in Russia do not resolve quickly: the full process — from commencement to distribution of assets — may extend to three to five years in complex cases. For foreign creditors, early enrolment and early application for interim relief are the two most significant levers for protecting position.

Q: What international conventions govern cross-border recognition of Russian unwinding orders?

A: There is no single multilateral convention governing the recognition of Russian insolvency measures abroad. Within the EAEU, developing mutual recognition frameworks apply but require separate domestic enforcement in each member state. For assets held in common-law or civil-law European jurisdictions, recognition of a Russian court order requires a separate application in each target jurisdiction, typically governed by bilateral treaties where they exist or by national private international law rules in their absence. The absence of an EU–Russia bilateral framework on mutual recognition of insolvency measures is a material structural obstacle. Foreign creditors with assets in both Russian and European entities should not assume that a Russian insolvency order has automatic or streamlined effect abroad.

Q: What is the most common reason unwinding proceedings fail for foreign creditors?

A: In the firm's experience, the most frequent cause of failure is an evidential deficit assembled too late. Foreign creditors who commence Russian proceedings — or enrol in existing insolvency proceedings — without a fully mapped corporate structure, without an understanding of the dates and consideration for the key transactions, and without a pre-formed strategy for the offshore discovery phase, frequently find that the Russian court process offers insufficient assistance in filling those gaps. The second most common cause is timing: creditors who act only once Russian proceedings are publicly known — after the debtor has filed for insolvency, after assets have already been transferred — enter the process at a structural disadvantage. The look-back periods and the interim-relief mechanisms have their greatest practical value when engaged early.

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 and institutional investors on the full spectrum of Russian asset-tracing and enforcement work: from offshore corporate investigation and interim freezing applications through to transaction challenges in Russian insolvency proceedings and cross-border enforcement coordination. Partner involvement is direct on every engagement, without delegation to junior fee-earners.

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 & Asset Tracing, Vetrov & Partners vetrovpartners.com/razina/

In over four years of advising foreign creditors on Russian asset recovery, one structural pattern has defined a disproportionate share of contested matters: the Cyprus intermediary. For much of the 2000s and 2010s, Cyprus-Russia corporate chains served a dual function — tax optimisation through treaty benefits and organisational flexibility through Cypriot holding vehicles. After 2022, both functions have been significantly disrupted. The double taxation treaty between Russia and Cyprus was suspended by Russia unilaterally, removing the treaty-rate withholding tax rates that underpinned many dividend-extraction and interest-payment architectures. More fundamentally, the geopolitical and regulatory environment has altered the assumptions on which these structures were built. For foreign creditors and distressed investors now seeking to enforce claims against Russian operating entities whose ownership runs through Cyprus, the recovery landscape is materially different from anything encountered in the preceding decade. This analysis sets out the key structural, procedural, and strategic considerations for those instructions.

For most of the period between Russia's accession to the double taxation treaty regime and 2022, the standard Cyprus-Russia corporate chain followed a recognisable template. A Cypriot holding company — typically a private limited company incorporated in Nicosia or Limassol — held shares in a Russian limited liability company or joint-stock company. The Cypriot entity was in turn held by an offshore vehicle in the British Virgin Islands, Cayman Islands, or a similar jurisdiction, sometimes with additional layers inserted for regulatory or succession-planning reasons. The Russian operating company held the productive assets: real estate, equipment, intellectual property, receivables, or operating licences.

This architecture served several consistent purposes. It provided reduced withholding tax rates on dividends and interest flows from Russia to Cyprus under the then-applicable treaty, confidentiality of beneficial ownership at the offshore level, and — critically for disputes — a structural distance between the Russian operating business and the ultimate creditor, making enforcement more complex for any claimant targeting the Russian assets from abroad.

After 2022, the architecture persists in many cases, but the treaty benefit that gave it much of its economic rationale is gone. Russia suspended its double taxation treaty with Cyprus, and the practical consequence is that withholding tax on dividend payments from Russian entities to their Cypriot parents now applies at standard domestic rates rather than the treaty-reduced rates. For creditors, this matters less than it does for beneficial owners — but it matters indirectly, because it changes the economics of maintaining the structure and therefore the incentive to restructure or dissolve it. Creditors who understand this dynamic are better placed to anticipate how debtor structures may be reorganised in the period between the creation of the debt and the initiation of formal proceedings.

For the purposes of cross-border asset recovery and enforcement against Russian entities operating within these chains, the key structural changes after 2022 are: the increased prevalence of intragroup asset transfers between the Russian operating entity and the Cypriot parent or its subsidiaries; changes to the Russian regulatory framework governing the approval of transactions with counterparties from "unfriendly states" (Cyprus is classified within this category under Russian regulatory practice); and the increased scrutiny by Russian courts of cross-border ownership chains in the context of insolvency, enforcement, and dispute proceedings.

If your claim runs against a Russian entity within a Cyprus-holding structure — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Russian arbitrazh courts — the commercial courts that handle both contentious corporate and enforcement matters — have developed a nuanced and, from a creditor's perspective, increasingly useful approach to Cyprus-Russia corporate chains. The general principle under Russian civil procedure is that a corporate entity is distinct from its shareholders, and that enforcement against a Russian operating company does not extend to its Cypriot parent or, by extension, to the offshore layer above it. However, this principle has been significantly qualified by developments in Russian insolvency legislation and by the expanding doctrine of subsidiary (vicarious) liability for controlling persons.

Under Russian insolvency legislation, the concept of a "controlling person" extends well beyond the direct shareholder. A Cypriot holding company that issued binding instructions to the Russian operating company's management, that approved major transactions, or that extracted value from the Russian entity through intragroup arrangements at non-arm's-length terms may be found liable as a controlling person in Russian insolvency proceedings. This is not a theoretical risk: Russian courts have, in a number of reported insolvency matters, held Cypriot holding entities — and in some cases, the beneficial owners of those entities — jointly and severally liable for the insufficiency of assets in the Russian insolvency estate. The practical significance for foreign creditors is considerable. A creditor whose Russian debtor has become insolvent and whose assets appear to have been transferred upward through the Cyprus chain prior to insolvency has a procedural avenue under Russian insolvency law that does not require initiating separate proceedings in Cyprus.

The limitation period considerations in this context are significant. Under Russian insolvency legislation, preferential transfer claims may extend to transactions completed within a defined period before the bankruptcy filing, and subsidiary liability claims against controlling persons have their own limitation mechanics. Foreign creditors who delay initiating proceedings risk losing access to these claims permanently — a dynamic that has been consistently underestimated by creditors unfamiliar with Russian insolvency practice.

Asset tracing within a Cyprus-Russia chain from the Russian side involves identifying the flow of assets — typically real estate, cash, receivables, IP rights, or operating licences — from the Russian operating entity to the Cypriot parent or to other group entities. The primary tools available under Russian procedure include: applications for interim measures (including freezing orders over assets held by the Russian entity or its affiliated persons); disclosure requests directed at the debtor's management; and, in insolvency proceedings, the insolvency administrator's extensive investigative powers. The Asset Tracing & Recovery practice requires combining these procedural instruments with external intelligence on asset location and beneficial ownership, which in Cyprus-Russia matters typically requires parallel coordination in Cyprus itself.

The intersection of Cyprus-Russia corporate structures with Russian insolvency proceedings is where the majority of contentious creditor instructions arise. When a Russian operating entity within a Cyprus chain files for insolvency — or when a creditor initiates involuntary proceedings — the insolvency administrator gains substantial investigative authority. This authority extends to examining the debtor company's transactions for a period prior to the filing, assessing whether asset transfers to affiliated parties (including the Cypriot parent) were made at undervalue or for the purpose of harming creditors, and pursuing annulment of such transactions under the Russian insolvency legislation's avoidance provisions.

For foreign creditors, the relevant question is typically one of priority and timing. In Russian insolvency proceedings, creditors must file proofs of claim within a defined period from the date on which the debtor is declared insolvent by the arbitrazh court. Missing this window does not extinguish the claim, but it relegates the creditor to a residual queue with materially reduced recovery prospects. Creditors holding claims governed by foreign law — including claims under English-law loan agreements or Cypriot shareholder agreements — must have those claims recognised by the Russian insolvency court before they can be admitted to the creditors' register. This recognition step involves procedural complexity that is frequently underestimated.

The insolvency administrator in a Russian proceeding has the power to challenge transactions that transferred assets from the Russian entity to its Cypriot parent — including dividend payments, management fee arrangements, intragroup loans, and transfers of intellectual property or real estate. Where the Cypriot entity received such transfers within the relevant look-back period and those transfers are found to have been at non-arm's-length terms or with the intent of reducing the assets available to creditors, the administrator can seek recovery of those assets into the Russian insolvency estate. This creates a strategic alignment of interests between the administrator and the creditors — but only if creditors are engaged in the proceedings early enough to influence the administrator's investigative agenda.

For creditors whose claims arose from trade finance or supply arrangements with the Russian entity, the insolvency of the Russian debtor is not necessarily the end of the recovery path. Where the Cypriot parent guaranteed the Russian entity's obligations — a structure that was common in pre-2022 trade finance documentation — creditors may have parallel enforcement options against the Cypriot entity in Cyprus, running concurrently with their participation in the Russian insolvency. The interaction between the two parallel processes requires careful coordination, particularly where the Cypriot entity is itself in financial difficulty. See the Restructuring & Insolvency practice for the insolvency-specific mechanics.

The suspension of the double taxation treaty between Russia and Cyprus has had a limited direct effect on the enforcement tools available to foreign creditors — enforcement rights derive from the underlying contractual or tortious claim, not from the treaty. However, the treaty suspension signals a broader deterioration in the bilateral legal cooperation framework that has practical consequences for creditors pursuing parallel proceedings in both jurisdictions.

Russia's regime for the recognition and enforcement of foreign judgments and arbitral awards operates on a reciprocity basis for state court judgments, and on New York Convention grounds for arbitral awards. Cyprus is a signatory to the New York Convention, and awards rendered in Cyprus by arbitral tribunals seated there — or awards from other New York Convention jurisdictions — are in principle enforceable in Russian arbitrazh courts. In practice, enforcement of foreign arbitral awards against Russian entities has become considerably more challenging since 2022, with Russian courts applying the public policy exception with greater frequency and less predictability than in the preceding period. The Russian Arbitration Centre (RAC) and the ICAC at the Russian Chamber of Commerce and Industry (MKAS) remain functioning domestic arbitral forums that may offer creditors a procedurally cleaner path to an enforceable award against a Russian entity than pursuing a foreign-seated award and then seeking its recognition.

"The creditor who understands that a Cyprus holding layer creates procedural complexity — not an impenetrable barrier — is the one who recovers. The key is identifying which Russian procedural instrument reaches the asset and deploying it before the debtor does." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For creditors who hold claims not governed by arbitration agreements, the procedural default is Russian state court litigation. Russian arbitrazh courts exercise jurisdiction over disputes involving Russian legal entities on the basis of the defendant's location in Russia — this jurisdictional basis is available regardless of the nationality of the claimant or the governing law of the contract. An English-law governed loan agreement between a Cypriot lender and a Russian borrower does not deprive the Russian arbitrazh court of jurisdiction over an enforcement claim; the Russian court will apply Russian conflict of laws rules to determine which substantive law governs, and will give effect to a choice of English law where it is validly made, subject to the public policy and mandatory rules limitations of Russian private international law.

The most effective enforcement strategy in Cyprus-Russia structures typically involves simultaneous action at multiple levels: initiating or joining Russian arbitrazh court proceedings against the Russian operating entity; where applicable, pursuing the Cypriot parent in the Cypriot courts for guarantee or shareholder liability claims; and deploying asset tracing intelligence to identify and freeze assets before the debtor can effect further transfers. The practical challenge is coordination — Russian procedural timelines, Cypriot court timelines, and the insolvency administrator's own agenda in any Russian insolvency do not naturally align. The matters described on the firm's Matters page illustrate how these parallel processes have been managed in practice.

If you are assessing enforcement options across a Cyprus-Russia structure — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The first and most important action for any foreign creditor with exposure to a Russian entity operating within a Cyprus-Russia corporate chain is to understand the current state of the structure. Many of these structures have been significantly altered since 2022 — Cypriot entities have been dissolved, shareholdings transferred to Russian residents, or assets moved into other jurisdictions to take advantage of Russia's parallel liberalisation of corporate links with non-Western jurisdictions. The structure as it existed at the time the debt was contracted may bear little resemblance to the structure that exists today. Asset tracing intelligence — both from public Russian registry sources and from legal proceedings in Cyprus and Russia — is the foundation of any enforcement strategy.

The second priority is assessing the limitation position. Limitation periods under Russian civil law differ depending on the type of claim and the forum in which it will be pursued. Claims in Russian insolvency proceedings have their own procedural deadlines that differ from the general civil limitation period. Creditors who have been monitoring a situation without taking formal steps are frequently surprised by how close to expiry their Russian-law claims may be.

Third, creditors should assess whether the existing contractual documentation — loan agreements, supply contracts, guarantee arrangements — is adequate to support proceedings in the forums that remain practically accessible. Documentation drafted for an earlier legal and regulatory environment may contain gap-filling problems when deployed in post-2022 Russian proceedings, particularly where governing law and jurisdiction clauses pointed to Cypriot or English law as the exclusive forum.

For cross-border clients seeking to understand how Russian courts currently approach structures of this type, the analysis at How Russian courts approach Cyprus-Russia corporate structures provides detailed procedural context. For clients tracking the evolving regulatory enforcement approach toward cross-border structures, the piece on Roskomnadzor enforcement trends and Cyprus-Russia structures addresses a related compliance dimension. The firm's Asset Tracing & Recovery practice page sets out the full range of tools and forums available under current Russian law.

To discuss the specific configuration of a Cyprus-Russia structure and the recovery options available — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• How Russian courts approach Cyprus-Russia corporate structures
• Roskomnadzor enforcement trends and Cyprus-Russia structures
• Asset tracing and recovery under Russian law: a creditor's guide

Q: Can a foreign creditor still trace and recover assets held through a Cyprus intermediary after the Russian entity has been reorganised?

A: Recovery remains possible after reorganisation, but the procedural path changes materially. Where a Russian operating entity has been reorganised — through merger, division, or conversion — its successor entity inherits its obligations under Russian civil law, and creditors retain their claims against the successor. Where the reorganisation was designed to place assets beyond the reach of creditors, Russian courts and insolvency administrators have tools to challenge it, particularly where the reorganisation occurred within the relevant look-back period. The key requirement is that the creditor acts before the limitation period on the relevant avoidance or successor-liability claim expires.

Q: What grounds does a Russian court typically accept for piercing a Cyprus holding structure in enforcement proceedings?

A: Russian courts do not apply a "piercing the corporate veil" doctrine in the English-law sense. The most effective grounds in practice are: first, the controlling person liability doctrine under Russian insolvency legislation, which extends liability to any entity that exercised de facto control over the debtor; second, the avoidance of transactions at undervalue or with an intent to harm creditors, which allows the insolvency administrator to recover assets transferred to the Cypriot holding entity; and third, the disregard of corporate form where the Cypriot entity was used purely instrumentally and without genuine independent economic function. Courts have been increasingly willing to scrutinise intragroup arrangements on this basis.

Q: How does the suspension of the Russia-Cyprus double taxation treaty affect recovery strategies for foreign creditors?

A: The treaty suspension affects the tax treatment of payments between Russian and Cypriot entities — principally dividend and interest flows. For creditors, the direct effect is limited: enforcement rights derive from the underlying contract or Russian law claim, not from the treaty. The indirect effect is more significant. The suspension has altered the economic rationale for maintaining Cyprus structures, which is driving restructuring activity that creditors must monitor closely. It has also contributed to a broader regulatory environment in which cross-border arrangements involving Cypriot entities receive heightened scrutiny from Russian regulators, which may be relevant to the admissibility of certain transaction structures as evidence in proceedings.

Q: What is the realistic timeline for cross-border asset tracing involving a Cyprus-Russia chain today?

A: Timelines vary considerably depending on the complexity of the structure, the co-operation of the Cypriot entities, and whether Russian insolvency proceedings are already under way. As a working estimate: initial asset tracing intelligence from Russian public registries can typically be assembled within two to four weeks. Obtaining disclosure through Russian court proceedings takes longer — from several months to over a year depending on the forum and the debtor's co-operation. Where parallel Cypriot proceedings are required, timelines in Cyprus are independent and subject to Cypriot procedural rules. Creditors should plan for a multi-year enforcement campaign in complex matters, and should take interim freezing steps early to prevent asset dissipation while the investigation progresses.

Q: Which Russian insolvency mechanisms are most relevant for creditors whose debtors used Cyprus vehicles to move assets?

A: The most relevant mechanisms are: the avoidance provisions under Russian insolvency legislation, which allow the administrator to set aside transactions with affiliated parties made at non-arm's-length terms or with the intent of harming creditors; the subsidiary liability claims against controlling persons, which can extend to the Cypriot holding entity and in some cases to the beneficial owners; and the creditors' committee process, which gives creditors with admitted claims a degree of oversight and influence over the administrator's investigative and recovery agenda. Creditors should seek admission to the creditors' register at the earliest possible stage to access these mechanisms and influence how they are deployed.

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

The firm's asset tracing and recovery practice advises foreign creditors, institutional investors, and distressed asset acquirers on recovering value from Russian entities and cross-border corporate structures. This includes asset tracing through Russian public registries and court proceedings, participation in Russian insolvency matters as creditor-side counsel, enforcement of foreign arbitral awards and court judgments, and coordinated parallel proceedings across multiple jurisdictions. With over 1,000 matters handled since inception, the team works on a partner-direct basis 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/

Anatomy of UAE real estate owned by Russian nationals: enforcement options

In advising foreign creditors on recovery against Russian national debtors, a consistent pattern emerges: Dubai and Abu Dhabi property registered in a debtor's name is identified late, approached incorrectly, or written off without a serious enforcement attempt. The reasons are understandable. UAE real estate held by Russian nationals sits at the intersection of three distinct legal systems — Russian law governing the debtor's obligations and domestic asset position, UAE property and insolvency law governing the registration and disposition of the asset, and the procedural law of whichever court or arbitral tribunal issued the underlying award or judgment. Navigating all three simultaneously, without experienced cross-border coordination, accounts for most enforcement failures in this asset class. This analysis sets out the structural and procedural landscape as it stands for foreign creditors in 2026, with particular attention to the tools available on the Russian law side and the coordination required to use them effectively.

Foreign creditors instinctively approach UAE real estate as a purely local enforcement question: obtain a UAE court order, register it against the Dubai Land Department title, proceed. That instinct is not wrong, but it is incomplete. Understanding the ownership structure on the Russian law side materially affects which enforcement routes are viable and which will be neutralised before they begin.

Russian nationals hold UAE property through several recurring structures. Direct registered ownership in the individual's name is the simplest and most enforcement-friendly. The Dubai Land Department register is publicly searchable by name, and title is clear. The more common structures among higher-net-worth debtors introduce layers. Offshore holding companies — historically Cypriot, now increasingly UAE free zone entities (DIFC, ADGM) or British Virgin Islands vehicles — sit between the individual and the registered title. The Russian national holds shares in the offshore company; the offshore company holds the property. Russian law reaches this structure through its controlled foreign corporation (CFC) rules, which require Russian tax residents to declare and, in some circumstances, pay tax on the undistributed income of foreign companies they control. CFC declarations, where filed, are a disclosure tool for creditors who can access them. Where they have not been filed — a compliance failure that is common — the structure may be harder to trace but the legal exposure of the beneficial owner remains.

A further variant involves joint ownership with family members, including spouses and adult children. Under Russian family law, property acquired during marriage is presumptively joint matrimonial property, regardless of whose name appears on the title. Where a Russian national debtor transferred UAE real estate to a spouse before the creditor's claim crystallised, or where the property was originally registered in a spouse's name, the transferability of that asset for enforcement purposes requires separate analysis.

The creditor's first task is therefore structural identification: who legally holds the UAE title, through what vehicle, and what is the debtor's relationship to that vehicle under Russian and UAE law respectively.

If you are a foreign creditor attempting to trace or enforce against UAE real estate held by a Russian national debtor, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Russian law does not ignore assets held abroad. For creditors pursuing Russian national debtors — whether under a Russian judgment, a foreign judgment recognised in Russia, or an arbitral award — the Russian legal framework provides a set of tools that are underused in cross-border enforcement practice.

Under Russian insolvency legislation, when a Russian national debtor enters bankruptcy proceedings before a Russian court, the bankruptcy trustee has a statutory obligation to identify and include in the bankruptcy estate all assets of the debtor, wherever located. Foreign real estate is not excluded. The trustee's practical ability to enforce against UAE property is limited by the absence of direct enforcement mechanisms — Russian courts cannot issue orders that UAE land registrars are obliged to obey. However, the identification and declaration of foreign assets in the bankruptcy estate creates a formal record that supports parallel UAE enforcement proceedings. It also establishes the debtor's estate comprehensively, which is important when creditors are competing for priority.

Outside insolvency, Russian civil procedure rules permit asset disclosure orders in the context of enforcement proceedings. Where a Russian court has issued a judgment against a debtor, the enforcement officer (судебный пристав) has authority to require the debtor to disclose all assets. Non-disclosure or false disclosure carries criminal exposure. More practically, the debtor is incentivised to comply or to challenge the judgment directly. For creditors, a documented asset disclosure — or a documented refusal — is useful evidence in UAE proceedings.

The challenge-to-transactions framework under Russian insolvency legislation is particularly relevant to cases where the debtor transferred UAE property to a related party before insolvency proceedings commenced. Transactions at undervalue and transactions made with the intent to defeat creditors can be challenged within defined look-back periods. A successful challenge in Russian proceedings does not automatically reverse the UAE land registration, but it creates a finding — that the transaction was void or voidable as a matter of the debtor's applicable law — that is relevant to any UAE court considering the same transaction.

Russian tax disclosure obligations (CFC declarations, foreign account reporting) provide a separate documentary trail. Creditors working with experienced Russian counsel can use these disclosure frameworks to reconstruct an asset picture that the debtor may have attempted to obscure.

"The fundamental asymmetry in cross-border enforcement against Russian nationals is this: the debtor's Russian law obligations to disclose and account for foreign assets are more extensive than most foreign creditors realise, and they are routinely underused." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement & Asset Protection, Vetrov & Partners

The enforcement routes available to a foreign creditor differ materially depending on the nature of the underlying instrument — Russian judgment, foreign judgment, or arbitral award — and on whether the creditor proceeds through Russian courts, UAE courts, or both in parallel.

Route A — Russian judgment enforced locally, UAE proceedings run in parallel. Where the creditor already holds a Russian court judgment, enforcement in Russia against Russian-domiciled assets is straightforward. UAE real estate is not directly reachable by Russian enforcement officers, but the Russian proceedings serve an important parallel function: the bankruptcy or enforcement file in Russia creates a formal legal record, generates asset disclosure obligations, and — if insolvency proceedings are opened — places the debtor under the supervision of a Russian bankruptcy trustee who has standing to bring cross-border cooperation requests.

Route B — UAE court proceedings initiated independently. A creditor with a claim against a Russian national who holds UAE real estate can bring an action in the UAE courts without any Russian law foundation, provided the claim is properly grounded under UAE law (typically in contract or tort). The UAE court can issue a judgment, attach the property under an interim order, and ultimately enforce against the registered title. The advantage is speed in jurisdictions where a judgment debtor has visible UAE assets. The disadvantage is that UAE proceedings in isolation do not address the Russian law position, and a debtor who successfully argues that the UAE courts lack jurisdiction — or who transfers the asset before an attachment order is registered — may defeat the UAE-only strategy.

Route C — Recognition and enforcement of foreign judgment or arbitral award in the UAE. Where the creditor holds a foreign judgment (from an English court, a German court, or another jurisdiction) or an international arbitral award, recognition and enforcement in the UAE is a viable path. The UAE is a party to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. UAE courts have recognised and enforced foreign arbitral awards issued by major institutional bodies. A recognised award creates a UAE judgment that can be executed against UAE-registered assets, including real estate. The limitation here is the grounds for non-recognition under the New York Convention framework as applied by UAE courts, which include public policy objections that have, in some reported instances, been applied more broadly than in comparable common-law jurisdictions.

Route D — Coordination of Russian and UAE proceedings. In practice, the most reliable enforcement outcome is achieved through coordinated parallel proceedings. Russian proceedings generate asset disclosure, establish the insolvency or judgment record, and create legal findings relevant to any transaction-challenge argument. UAE proceedings use the Russian-side record as supporting evidence, and the UAE court's interim attachment order — registered with the Dubai Land Department or Abu Dhabi Department of Municipalities — prevents a disposition of the asset while the substantive claim proceeds. Neither set of proceedings is complete without the other for a well-structured enforcement strategy.

Creditors who delay initiating enforcement proceedings risk losing their position to other creditors, to secured lenders registered against the UAE title, or to the debtor's own restructuring steps — and under Russian insolvency legislation, the look-back window for challenging preferential transfers is measured in years, not months.

Foreign creditors with Russian national debtors holding UAE property need coordinated advice from the outset. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This is among the most frequently asked questions in cross-border enforcement practice, and the short answer is: not directly. Russian courts have no treaty-based mechanism that compels UAE land registrars or courts to give effect to a Russian interim order. However, the question deserves a more calibrated answer than a simple no, because the Russian court process can contribute meaningfully to a UAE freeze strategy.

A Russian court hearing a civil claim against a debtor can grant interim measures — including a prohibition on the disposal of assets — under Russian civil procedure rules. Where the debtor is a Russian national, that interim order is personally binding on the debtor. It does not operate in rem against the UAE title, but it operates in personam against the debtor. A debtor who disposes of UAE real estate in breach of a Russian court's interim order is exposed to contempt and criminal liability under Russian law. More importantly, a transfer made after the Russian court order was issued — and of which the counterparty had notice — is potentially challengeable as a fraudulent disposition in both Russian and UAE proceedings.

The interim order also has evidential value. In UAE court proceedings seeking a precautionary attachment (hajar احتياطي) under UAE law, the existence of a Russian court proceeding and interim order is relevant context. It demonstrates that the claim is live, that the debtor has been served, and that the risk of asset dissipation has been formally recognised by a court of the debtor's home jurisdiction. UAE judges have discretion in precautionary attachment applications; a well-constructed filing that includes the Russian court record strengthens the application.

Separately, the DIFC courts — which have a broad jurisdiction by agreement, including jurisdiction over cases where the parties have submitted — have a developed common-law interim relief jurisprudence. A DIFC court order has direct enforceability within the DIFC and, through the DIFC-ADGM gateway and the DIFC-onshore gateway mechanism, can reach assets in the wider UAE. For creditors whose underlying agreement includes a DIFC or ADGM arbitration clause, interim relief in those jurisdictions is a more direct route to freezing UAE-registered property.

The anatomy of enforcement against UAE real estate owned by Russian nationals reduces to a sequencing and coordination problem. The legal tools exist on both the Russian and UAE sides; the enforcement failures the firm sees most frequently arise from fragmented instruction — separate counsel in each jurisdiction working without a shared strategy — or from late instruction, after the debtor has had time to move the asset or encumber the title.

A structured approach for foreign creditors proceeds broadly as follows. Before any proceedings are issued, the creditor's advisers should map the ownership structure: is the property held directly or through a vehicle? Is there a registered mortgage or other security against the UAE title? Are there co-owners whose consent or position must be considered? In parallel, the Russian law position should be assessed: is the debtor a Russian tax resident? Have CFC declarations been filed? Has the debtor undergone or commenced Russian bankruptcy proceedings? The answers to these questions determine which enforcement routes are available and in what order.

Where the debtor is solvent and the enforcement objective is recovery rather than insolvency, the priority is speed of attachment. A UAE precautionary attachment application, supported by a strong evidential record — including any Russian court proceedings, any Russian judgment, any CFC disclosure documents — gives the creditor the best prospect of securing the asset before a transfer or encumbrance occurs.

Where the debtor has already entered Russian insolvency proceedings, the creditor should ensure it has filed a claim in the Russian insolvency process, even if recovery from the Russian estate is unlikely to be complete. Filing preserves standing and access to the insolvency trustee's asset identification work. The trustee's findings about UAE property — which the trustee is obliged to pursue — can be incorporated into UAE proceedings.

Where there is evidence of asset dissipation — transfers to related parties at below-market consideration, or mortgages created in favour of connected lenders — both Russian transaction challenge rules and UAE fraudulent transfer principles should be considered concurrently. The look-back periods and legal standards differ between the two systems, and a transaction that is beyond challenge in one system may still be vulnerable in the other.

The firm's Asset Tracing & Recovery practice coordinates with foreign counsel in the UAE and in other relevant jurisdictions to deliver a joined-up enforcement strategy. Creditors who have already initiated proceedings in one jurisdiction and are now seeking to extend enforcement to another are a significant part of the practice's caseload.

To discuss a coordinated Russian-UAE enforcement strategy, contact the team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

• Regulatory update: UAE real estate owned by Russian nationals — what changed
• Foreign creditors and UAE real estate owned by Russian nationals: a practical briefing
• Asset Tracing & Recovery — practice overview

Q: As a foreign creditor, can I enforce against Dubai real estate owned by a Russian national debtor without first obtaining a Russian court judgment?

A: Yes. A Russian court judgment is not a prerequisite for enforcement proceedings in the UAE against UAE-registered property. A creditor with a contractual claim can bring proceedings directly in the UAE courts or — where the underlying agreement provides for it — in DIFC or ADGM arbitration or litigation. The UAE courts have jurisdiction to hear claims and to issue precautionary attachment orders against UAE-registered assets without any Russian court involvement. That said, a Russian judgment or arbitral award, if already in existence, strengthens the evidentiary position in UAE proceedings and may accelerate the attachment process by demonstrating that the claim has been adjudicated.

Q: What documents does a foreign creditor need to trace UAE real estate held through an offshore company?

A: Tracing property held through an intermediary company requires documentary work at several levels. At the UAE level, the Dubai Land Department register records the legal title holder. If the title is in a company name, the creditor must identify who owns or controls that company — which typically requires corporate registry searches in the relevant offshore jurisdiction (BVI, Cayman, ADGM, DIFC). At the Russian law level, CFC declarations filed by the Russian national debtor with the Federal Tax Service are a disclosure source — these declare beneficial ownership of foreign entities meeting the relevant control thresholds. Access to those declarations for enforcement purposes is a matter of Russian procedural law; counsel with experience in Russian enforcement proceedings can advise on the applicable route.

Q: Under Russian law, how far back can a creditor challenge a transfer of UAE real estate made before insolvency proceedings?

A: Under Russian insolvency legislation, the look-back periods for challenging transactions vary by the type of challenge. Transactions at undervalue with related parties can be challenged for a period running back several years from the insolvency filing date. Transactions with unconnected third parties at below-market consideration carry a shorter look-back. Transactions made with the demonstrated intent to defeat creditors — regardless of the relationship between the parties — attract the longest look-back periods. These periods run from the date the bankruptcy petition is filed, not from the date of the creditor's own claim. The creditor's counsel should assess which basis of challenge is available and whether the transaction falls within the applicable period, before investing in UAE challenge proceedings that may be time-barred on the Russian side.

Q: Can Russian insolvency proceedings produce findings that are useful in UAE courts?

A: They can. Where a Russian bankruptcy trustee makes a formal finding — in the course of the insolvency proceedings — that a debtor transferred UAE property as part of an asset-stripping pattern, that finding is a piece of evidence that a UAE court may receive and consider. It is not automatically binding on the UAE court, which applies its own law, but it provides a factual record built by a state-appointed officer under judicial supervision. This is particularly useful where the creditor cannot independently reconstruct the transfer history and relies on the trustee's investigative powers to do so.

Q: What is the role of a Russian-qualified law firm in a UAE enforcement strategy?

A: The Russian-law dimension of the enforcement is not ancillary — it is often the structural foundation on which the UAE proceedings depend. Russian counsel advise on the debtor's asset disclosure obligations, the validity and enforceability of the Russian judgment or award, the grounds for challenging prior transactions under Russian insolvency law, the CFC disclosure framework, and the coordination of Russian enforcement proceedings with UAE counsel. In the firm's experience advising on distressed assets and Russian law matters of this kind, the most common avoidable failure is the absence of a Russian law assessment at the outset — before the UAE proceedings are structured and before the debtor's response can be anticipated with the benefit of Russian procedural knowledge.

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 distressed-debt buyers on the identification, tracing, and enforcement of assets held by Russian nationals in Russia and across multiple foreign jurisdictions, including the UAE. The practice combines Russian procedural expertise with coordinated cross-border counsel relationships in key enforcement jurisdictions. With over 1,000 matters handled since inception, the team provides direct partner-level 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 & Asset Protection, Vetrov & Partners vetrovpartners.com/razina/

In a decade of advising foreign creditors on distressed assets and cross-border recovery, one structural problem recurs more than any other: the creditor who has already secured a favourable judgment — in London, Frankfurt, or Amsterdam — but has not yet coordinated a corresponding enforcement position in Russia. By the time Russian proceedings are initiated, assets that were traceable six months earlier have migrated, been pledged to related parties, or vanished into a subsidiary structure that the debtor has placed in administration. Coordinating enforcement across Russia and foreign jurisdictions is not a sequencing question; it is a simultaneity question, and foreign creditors who treat it otherwise bear the cost of that misunderstanding in recovery rates that fall far short of what the underlying claim warranted.

For foreign creditors holding claims against Russian debtors, the enforcement landscape presents a distinctive challenge: the Russian legal framework operates on its own procedural logic, with its own timelines, asset-protection mechanics, and court culture, while the foreign jurisdiction applies a parallel set of rules that may be internally coherent but was not designed to interlock with Russian procedure. The result is a gap — sometimes a critical one — between the moment at which a foreign award or judgment becomes enforceable abroad and the moment at which the creditor has taken the steps necessary to protect assets inside Russia.

The gap matters because Russian insolvency legislation allows preferential transfer claims to be brought in respect of transactions completed up to three years before a bankruptcy filing. A debtor who anticipates enforcement has considerable scope to move assets within that window — and, in practice, asset migration typically accelerates in the months immediately preceding an insolvency application. Creditors who do not map Russian-situs assets and initiate interim protection measures concurrently with their foreign proceedings will frequently find that the Russian enforcement estate has been materially diminished by the time they arrive in a Russian court.

The practical answer is a coordination structure: a sequenced but simultaneous strategy in which foreign counsel and Russian counsel agree on common objectives, share asset intelligence, and calibrate the timing of each procedural step against the other jurisdiction's calendar. This is not a theoretical aspiration — in recent matters, the firm has seen coordinated multi-jurisdictional strategies produce materially better recovery outcomes than sequenced approaches in which Russian proceedings were initiated only after foreign enforcement was complete.

For foreign creditors considering enforcement against Russian-situs assets — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Coordinating enforcement across Russia begins with understanding what the Russian procedural system will and will not do by default. Russian law does not automatically recognise or give effect to foreign court judgments or arbitral awards. Recognition and enforcement requires a separate application to the Russian arbitrazh court (commercial court) with jurisdiction over the debtor's registered seat or the location of its assets. The basis for that application depends on the type of foreign decision involved.

For foreign arbitral awards, the New York Convention 1958 provides the primary framework, and Russia is a signatory. In practice, Russian courts have applied the Convention's grounds for refusal — particularly public policy — with varying degrees of rigour over different periods, and applicants must be prepared to address arguments that the underlying dispute was not arbitrable under Russian law or that enforcement would contravene Russian public policy. The procedural burden on the creditor is meaningful: the application must be accompanied by a certified translation, an authenticated copy of the award, and — where required — evidence of the arbitration agreement. Procedural defects at this stage routinely generate delays of six to nine months.

For foreign court judgments (as distinct from arbitral awards), enforcement in Russia requires either a bilateral treaty providing for mutual recognition or a demonstration of reciprocity. Russia has concluded bilateral recognition treaties with a limited number of states, and many common creditor jurisdictions — including the United Kingdom and the United States — are not among them. In the absence of a treaty, Russian courts have on occasion applied the reciprocity principle, but this route is uncertain and should not be treated as a reliable enforcement channel without specific prior analysis of the target jurisdiction's relationship with Russia.

For creditors whose claims arise from contracts governed by Russian law or performed in Russia, a direct action in the Russian arbitrazh courts — or under a Russian arbitration clause pointing to the ICAC (MKAS) or the Russian Arbitration Centre (RAC) — may provide a more direct route than recognition of a foreign award, and avoids the recognition stage entirely.

Asset tracing is the intelligence layer that makes coordinated enforcement coherent. Without a clear map of where assets are held — and in what form, under what legal structure, and subject to what encumbrances — enforcement efforts in any jurisdiction are inherently reactive. In the context of a Russian debtor with offshore holdings, the tracing exercise typically spans at least two layers: the Russian operating entity and its domestic assets, and the holding structure — often Cyprus, the Netherlands, or a similar EU jurisdiction — through which the debtor's ultimate beneficial owner controls the group.

In the Russian layer, asset tracing draws on publicly available sources — the Unified State Register of Legal Entities (EGRUL), the Federal Bailiff Service's enforcement database, Rosreestr (for real estate), and the Federal Tax Service's published data on tax arrears and enforcement. These sources are not comprehensive, but they provide a baseline picture of registered assets and existing encumbrances. Gaps in the publicly available record should be treated as informative: a Russian entity with significant commercial turnover but minimal registered fixed assets has almost certainly structured itself to hold value at a different level of the group.

In the offshore layer — particularly for assets held through Cyprus or Dutch structures — the tracing exercise connects to recognition proceedings in those jurisdictions. A creditor who has already obtained a favourable award in a seat such as London or Paris should, in parallel with Russian recognition proceedings, be pursuing freezing orders or equivalent interim relief in the holding-company jurisdiction. The coordination point is timing: Russian interim measures are available from the arbitrazh court, but they require an active Russian claim. Creditors who file for recognition of a foreign award in Russia may simultaneously apply for interim measures — asset freezes, attachment of bank accounts, prohibition on disposal — within the same proceedings.

"Coordinating enforcement across jurisdictions is, above all, a question of sequencing: the creditor who maps assets and files for interim relief simultaneously in Russia and abroad preserves options that are difficult or impossible to recover once lost." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The practical lesson is that interim measures in Russia should be considered at the moment of filing — not as an afterthought once recognition is granted. Russian courts may grant attachment orders on the basis of a foreign award recognition application, and the window between filing and the debtor's awareness of proceedings is typically narrow. Counsel who have prepared the attachment application in advance of filing can move within that window; those who have not will find that the debtor has had notice and time to respond.

For creditors requiring coordinated interim relief across Russia and abroad — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The Eurasian Economic Union (EAEU) and the Commonwealth of Independent States (CIS) have produced treaty frameworks that are directly relevant to foreign creditors whose debtors hold assets across post-Soviet states. These frameworks are not widely understood outside the region, and they represent a meaningful enforcement resource that is frequently overlooked in strategies developed primarily from a Western legal perspective.

Within the EAEU — comprising Russia, Kazakhstan, Belarus, Armenia, and Kyrgyzstan — court judgments issued by the courts of member states benefit from a simplified recognition and enforcement procedure under the Treaty on the EAEU. Commercial court decisions from Kazakhstan, for example, may be enforced in Russia without the full New York Convention recognition procedure, and vice versa. This is particularly relevant for creditors whose debtors maintain operating assets in multiple EAEU states: a single enforcement strategy that coordinates Russian proceedings with Kazakhstani or Belarusian proceedings may produce broader asset coverage than a Russia-only approach.

The CIS Convention on Legal Assistance and Legal Relations in Civil, Family, and Criminal Cases (the Minsk Convention and its successor instruments) provides a further layer of mutual recognition for civil judgments among CIS member states. The practical effect for asset tracing and enforcement is that a creditor who has obtained a judgment in a Russian arbitrazh court can, in principle, enforce that judgment in other CIS states without re-litigating the merits. This extends the geographic reach of a Russian enforcement order — a consideration that is most relevant when the debtor's assets are distributed across the former Soviet space rather than concentrated in a single jurisdiction.

The limits of these frameworks should not be understated. Recognition under EAEU and CIS instruments is still subject to procedural requirements and local court oversight. The treaty protections do not override local insolvency proceedings, and a debtor who files for bankruptcy in a member state can use that proceeding to complicate or delay enforcement under a foreign judgment. Coordination with local counsel in each jurisdiction remains essential; the treaty framework provides the legal basis but not the procedural execution.

For creditors whose debtors are active in multiple EAEU or CIS jurisdictions, a multi-seat strategy — in which simultaneous applications are made in each jurisdiction where material assets are located — often produces the most comprehensive asset freeze, limiting the debtor's ability to consolidate assets in whichever jurisdiction enforcement has not yet reached.

The difference between a coordinated enforcement strategy and an ad hoc multi-jurisdiction response is largely a matter of preparation: the legal architecture for simultaneous action in Russia and abroad must be assembled before enforcement commences, not after. The following practical considerations reflect the firm's experience in acting for foreign creditors in coordinated enforcement matters.

The first priority is asset mapping. Before any proceeding is filed, a detailed picture of the debtor's asset footprint — across Russia, the CIS, and any holding-company jurisdiction — should be assembled using publicly available sources supplemented, where circumstances permit, by intelligence from the creditor's commercial relationship with the debtor. The asset map drives decisions about where to file first, which interim measures are most valuable, and which jurisdictions represent the highest recovery risk if enforcement is delayed.

The second priority is counsel coordination. Where the enforcement strategy spans multiple jurisdictions, the Russian counsel and foreign counsel must operate as a functional unit. This means agreement on a shared timeline, regular information exchange, and — critically — alignment on the trigger points at which each jurisdiction's proceedings should be initiated. Russian interim measures become available at a specific procedural moment; missing that moment typically requires starting the application afresh, at a cost in both time and the element of surprise.

The third priority is insolvency monitoring. Russian debtors who are subject to enforcement pressure will frequently file for voluntary insolvency as a defensive measure. The filing of a bankruptcy petition in Russia triggers an automatic stay on individual enforcement actions; creditors who have not yet filed their claims in the insolvency proceedings — or who have not obtained interim measures before the stay takes effect — will find their position materially weakened. Monitoring the Federal Bailiff Service database and the Unified Federal Register of Bankruptcy Information (Fedresurs) for signs of imminent insolvency filing is a standard step in any creditor-side mandate of this nature.

The fourth priority is jurisdictional sequencing. In matters where the creditor holds both a foreign award and a parallel claim under Russian law or a Russian arbitration clause, the sequencing question — which proceeding to lead, and which to use as supporting pressure — requires careful analysis. Leading with the Russian proceeding may produce faster attachment, but it also puts the creditor's hand on the table; leading with a foreign freezing order in a holding-company jurisdiction may produce broader coverage, but it requires Russian counsel to be ready to file for recognition and interim measures in Russia within days.

The fifth consideration is communication discipline. Debtors who are subject to coordinated enforcement across multiple jurisdictions will frequently attempt to negotiate separately with counsel in each jurisdiction, seeking to agree arrangements that are inconsistent across jurisdictions — accepting a payment plan in one forum while dissipating assets through another. Creditors should ensure that all communications with the debtor and its representatives are channelled through a single point, and that any proposed settlement or standstill is analysed for its effect on proceedings in all jurisdictions before it is accepted or rejected.

For in-depth analysis of the procedural mechanics at each stage, see the firm's related analysis on Court practice shifts in coordinating enforcement across jurisdictions and the accompanying risk review at Key risk points in coordinating enforcement across Russia. The full Asset Tracing & Recovery practice page sets out the firm's approach to mandates of this kind. Creditors in Restructuring & Insolvency situations involving Russian entities may also find the insolvency-specific analysis useful.

For an overview of representative matters involving cross-border recovery, see the firm's Matters Hub.

For creditors assembling a coordinated enforcement strategy across Russia and foreign jurisdictions — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Court practice shifts in coordinating enforcement across jurisdictions
• Key risk points in coordinating enforcement across Russia
• Asset Tracing & Recovery: the firm's approach to cross-border mandates

Q: Can a foreign creditor obtain interim asset-freezing relief in Russia before a final award or judgment is recognised?

A: Yes, in principle. Russian procedural law permits interim measures — including asset freezes and prohibitions on disposal — to be granted within recognition proceedings before a final recognition order is issued. The application must demonstrate a risk that the debtor will dissipate assets before enforcement can be completed, and the court has discretion as to whether to grant relief. In practice, the strength of the application depends on the quality of the evidence presented and the speed with which counsel moves after filing. The window between the debtor learning of the proceedings and the court being asked to act on an interim application is typically short. For creditors relying on this mechanism, interim measures must be prepared as part of the initial filing package — not as a follow-on step.

Q: Does Russia recognise and enforce court judgments from the United Kingdom, the United States, or other common creditor jurisdictions without a bilateral treaty?

A: Russia does not have bilateral mutual recognition treaties with the United Kingdom or the United States, and recognition of court judgments from those jurisdictions therefore depends on the reciprocity principle. Russian courts have applied reciprocity in some instances, but the route is procedurally uncertain and subject to judicial discretion. Foreign arbitral awards from those jurisdictions fare better: Russia is a party to the New York Convention, which provides a more structured recognition framework. Creditors holding London arbitration awards or ICC awards seated in Western Europe generally have a more predictable recognition route than those relying on court judgments from non-treaty jurisdictions. In each case, specialist analysis of the specific award or judgment and its recognition prospects in Russia is essential before enforcement strategy is finalised.

Q: How does the EAEU enforcement framework differ from standard cross-border enforcement for creditors pursuing debtors across multiple post-Soviet states?

A: Within the EAEU, court judgments from member states benefit from a simplified recognition procedure under the EAEU Treaty, which removes the need for a full merits re-examination in the enforcement jurisdiction. This materially reduces both the time and the procedural burden of multi-state enforcement compared with the standard New York Convention route or bilateral treaty route. For creditors whose debtors hold assets in Russia, Kazakhstan, Belarus, Armenia, or Kyrgyzstan, a coordinated strategy that uses EAEU treaty recognition across multiple member states simultaneously — rather than sequentially — can significantly compress the enforcement timeline and reduce the debtor's opportunity to shift assets between EAEU jurisdictions. CIS convention instruments extend a similar (though procedurally less streamlined) framework across a broader group of post-Soviet states.

Q: What is the risk of a Russian debtor filing for voluntary insolvency to block foreign enforcement proceedings?

A: The risk is real and is a standard consideration in any creditor-side mandate involving a Russian debtor under enforcement pressure. Once a bankruptcy petition is accepted by the Russian arbitrazh court, an automatic stay on individual enforcement actions takes effect, and unsecured creditors must register their claims in the insolvency proceedings rather than pursuing separate enforcement. Creditors who have not yet obtained enforceable attachments in Russia before the stay takes effect will typically lose priority relative to secured creditors and the bankruptcy estate's expenses. The most effective mitigation is speed: obtaining attachment orders in Russia before the insolvency filing, monitoring Fedresurs for signs of imminent filing, and where possible filing a creditor's own insolvency application before the debtor does so voluntarily — a step that preserves more control over the insolvency timeline.

Q: Should a foreign creditor lead with Russian enforcement proceedings or with proceedings in the debtor's holding-company jurisdiction?

A: There is no universal answer, and the question requires analysis of the specific asset distribution, the nature of the claim, and the procedural options available in each jurisdiction. As a general framework: leading with a freezing order in the holding-company jurisdiction (e.g. Cyprus, the Netherlands, or Luxembourg) provides broader group-level asset coverage and may be obtained on a without-notice basis in many civil law systems. However, it does not directly attach Russian-situs assets. Leading with Russian attachment proceedings provides more targeted coverage of domestic assets but telegraphs the enforcement strategy to the debtor at an earlier stage. In practice, the strongest outcomes result from simultaneous filing — a without-notice holding-company freezing order on one day, followed immediately by a Russian attachment application, so that the debtor has no interval in which to move assets between the two layers.

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 distressed asset holders on cross-border enforcement against Russian-situs assets. This includes coordinating enforcement across Russia and foreign jurisdictions, asset tracing across EAEU and CIS states, parallel proceedings management, and insolvency creditor-side representation. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of the Russian legal framework with 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/

When a counterparty begins moving assets across its Russian subsidiary network, the creditor's instinct is to seek a worldwide freezing order from an English court. The order is granted. It names Russian-situated bank accounts, real estate, and receivables. And then — for many creditors — the work of actually preserving those assets begins in earnest, against a Russian legal framework that neither recognises the English order directly nor offers a straightforward substitute. Foreign creditors who treat a worldwide freezing order as the end of the problem, rather than the beginning of the enforcement strategy, routinely find that Russian-situated assets have been dissipated before any parallel Russian interim measure is in place.

If you are a foreign creditor with Russian-situated assets under threat of dissipation — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

A worldwide freezing order issued by an English court is an in personam injunction. It binds the respondent personally, wherever that person or entity is located, and prohibits dealing with assets up to the stated ceiling. It is, in principle, one of the most powerful interim remedies available to a creditor in international litigation.

The jurisdictional reach of the order, however, is a function of English law and English contempt jurisdiction. It binds entities over whom the English court has personal jurisdiction. For a Russian company that has no presence in England, has not submitted to English jurisdiction, and whose assets sit within the Russian Federation, the English court's in personam order operates in a legal vacuum. Russian law does not give direct effect to foreign interim injunctions. The Russian arbitrazh courts — which handle commercial disputes between legal entities — have no mechanism for recognising and enforcing a foreign freezing order as such.

This does not render a worldwide freezing order without value in cross-border Russian asset recovery. Its value is indirect: it constrains the respondent's behaviour globally, it captures assets held through entities subject to English jurisdiction, and it creates a documentary and factual record that supports a parallel application in Russia. But it is not a substitute for Russian-law interim measures, and treating it as one is among the most consequential errors a foreign creditor can make when pursuing distressed assets in Russian law.

Russian civil and commercial procedure provides its own interim measures regime, broadly analogous to freezing relief in common law systems but operating through distinct procedural mechanics. Applications are made to the arbitrazh court with substantive jurisdiction over the underlying claim — or, in limited circumstances, to the court that will hear the recognition and enforcement proceedings.

The standard Russian interim measure for asset preservation is an arrest (arest) of the respondent's identified assets: bank accounts, real estate, securities holdings, or receivables due from named debtors. The application is made ex parte in most cases and the court has discretion to grant it on the same day, particularly where the applicant can demonstrate urgency and substantiate a risk of dissipation.

Under Russian insolvency legislation, preferential transfer claims may be brought for transactions completed up to three years before a bankruptcy filing — a window that creditors unfamiliar with Russian law frequently underestimate when assessing what interim measures are still available to them.

Russian procedure requires the applicant to identify the assets specifically. A Russian court will not grant a general asset freeze equivalent to the ceiling-based structure of an English worldwide freezing order. This specificity requirement has practical consequences: a foreign creditor must have traced, identified, and documented Russian-situated assets before the interim application is made. The tracing exercise is not optional — it is a prerequisite to effective relief under Russian law.

Security for the respondent's potential losses must also be considered. Russian courts typically require the applicant to provide counter-security — a bank guarantee or a deposit — calibrated to the value of the assets frozen. This adds a cost dimension to interim measure strategy that foreign creditors should factor into their recovery economics from the outset.

For assistance identifying and documenting Russian-situated assets before an interim application — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Russian arbitrazh courts do not recognise foreign interim injunctions as enforceable orders. This position reflects both the absence of a bilateral treaty between Russia and most common law jurisdictions providing for interim measure recognition, and the more general principle that Russian procedural law applies to proceedings before Russian courts, regardless of the existence of a parallel foreign order.

"A worldwide freezing order obtained in London creates legal pressure on the respondent personally, but it creates no legal obligation on Russian banks, registrars, or counterparties — and no Russian court will enforce it as issued. The work of asset preservation in Russia requires a Russian procedural instrument from the outset." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

There are two partial exceptions worth noting for foreign creditors operating in this space. First, where the foreign order is obtained from a court that has issued a final judgment that Russia will recognise — under a bilateral investment treaty or a treaty on legal assistance — the underlying judgment may be recognised, and interim measures ancillary to recognition proceedings may be available. Second, where the respondent is a party to ICAC (MKAS) proceedings in Moscow or RAC arbitration, interim measures may be sought from the arbitral tribunal itself, which has its own powers under Russian arbitration law. Neither route eliminates the need for a parallel Russian court application; both may supplement it.

In practice, the most effective approach for foreign creditors with Russian-situated assets is a concurrent strategy: the worldwide freezing order is pursued before the English court to capture globally-held assets and to constrain the respondent's broader behaviour; a simultaneous or immediately following application for arest is made to the relevant Russian arbitrazh court on the basis of specifically traced and documented Russian assets. The two instruments are complementary, not interchangeable.

The categories of Russian-situated assets most commonly the subject of interim preservation applications include: balances in accounts held at Russian credit institutions; real property registered in the Unified State Register of Real Property (EGRN); shares in Russian limited liability companies or joint stock companies, held through the corporate register; receivables due to the respondent from identified Russian debtors; and equipment or inventory held at identified Russian premises.

Tracing these assets before the application requires a combination of public registry searches and, where available, information obtained through the disclosure mechanisms attached to a worldwide freezing order. The disclosure obligations on a respondent subject to an English worldwide freezing order — to disclose the nature, value, and location of assets globally — are a significant and underused tool for generating the asset map that Russian procedure requires.

Russian public registries for real property and corporate shareholdings are accessible, though procedural restrictions on third-party access have tightened in recent years. For bank account identification, the picture is more complex: Russian banks do not disclose account details without either a court order or a formal inquiry from a Russian enforcement authority. This creates a sequencing problem for foreign creditors — they need bank account details to make a successful arest application, but obtaining those details independently requires a prior Russian court process. The standard solution is to focus the initial arest application on the assets that can be traced from public sources — real property, corporate stakes, identified receivables — and to use the enforcement proceedings to generate further disclosure of account information.

The asymmetry between the worldwide freezing order's global reach and its limited direct effect in Russia means that the enforcement strategy must be designed with Russian-law mechanics in mind from the moment a claim is contemplated — not retrofitted once the English order is in hand.

In practice, this means the following. First, before or simultaneously with the English freezing application, a Russian asset tracing exercise should be initiated using public registries and any available commercial intelligence. Second, the disclosure obligations under the worldwide freezing order should be actively enforced to generate a Russian asset map, with contempt sanctions held in reserve as leverage. Third, the Russian arest application should be filed on the basis of specifically identified assets, supported by evidence of the underlying claim and of the risk of dissipation — the same factual record that underpins the English application is largely usable before the Russian court, with appropriate translation and legalisation. Fourth, where the respondent has Russian corporate assets — shares in Russian entities — the interim measure should include a prohibition on participation in corporate governance decisions that might affect asset value, such as the approval of dividends, asset sales, or reorganisation resolutions.

In a recent matter, the firm acted for a European trade creditor whose Russian counterparty had begun a series of intragroup asset transfers ahead of an anticipated insolvency filing. The firm obtained an arest over identified real property and corporate stakes within the Russian arbitrazh court proceedings, coordinated with English counsel on the worldwide freezing order application, and succeeded in preserving assets sufficient to cover the principal debt. The matter resolved within fourteen months of instruction.

Foreign creditors who approach Russian asset recovery with a single-jurisdiction mindset — whether exclusively English or exclusively Russian — consistently achieve worse outcomes than those who treat the two regimes as complementary instruments requiring concurrent activation. The coordination overhead is real, but so is the recovery differential.

For a structured assessment of your Russian asset recovery position — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Worldwide Freezing Orders and Russian-Situated Assets: Legislative Update
• A Practical Guide to Worldwide Freezing Orders for Foreign Creditors in Russia
• Asset Tracing and Recovery in Russia: Practice Overview

Q: Will an English worldwide freezing order prevent a Russian company from dealing with its Russian bank accounts?

A: Not directly. An English worldwide freezing order binds the respondent personally through the contempt jurisdiction of the English court. A Russian company with no presence in England and whose accounts are held at Russian credit institutions is not subject to that contempt jurisdiction in any practical sense — and Russian banks are under no obligation to freeze accounts on the basis of a foreign court order. To preserve Russian bank account balances, a separate arest application must be made to the competent Russian arbitrazh court on the basis of specifically identified account details. The English order may generate disclosure obligations that help locate those accounts, but it does not itself freeze them.

Q: How quickly can a Russian arbitrazh court grant an interim asset freeze?

A: Russian arbitrazh courts can and do grant arest applications on an ex parte basis, sometimes on the day of filing or within a matter of days, where the applicant demonstrates urgency and substantiates a risk of dissipation. In practice, preparation of the application — which must identify assets specifically and include evidence of the underlying claim and the dissipation risk — typically takes one to two weeks for a well-documented matter. Courts in different circuits vary in their receptiveness to foreign creditor applications; the Siberian and Ural circuit courts handle a material volume of creditor-side commercial litigation and have developed a workable body of practice on interim measures in cross-border matters.

Q: Can a foreign creditor apply directly to a Russian court for interim measures, or must it have an existing Russian claim?

A: A foreign creditor may apply to a Russian arbitrazh court for interim measures in support of a claim that is either already pending before that court or is being brought there simultaneously. In limited circumstances — principally in connection with recognition and enforcement of a foreign judgment or arbitral award — interim measures may be sought as ancillary to the recognition proceedings themselves. Where the underlying dispute is subject to international arbitration at ICAC or the RAC, the arbitral tribunal also has power to order interim measures under Russian arbitration law. A foreign creditor whose underlying dispute will be resolved entirely in a foreign forum without any Russian recognition proceedings faces the most constrained position and should take early advice on how to establish the necessary jurisdictional anchor.

Q: What assets are most straightforward to freeze under Russian procedure?

A: Real property registered in the Russian State Register and corporate stakes in Russian limited liability companies or joint stock companies are the most tractable categories — both can be identified from public registries and are subject to registration-based freeze mechanisms that are well understood by Russian courts. Shares in joint stock companies held through a registrar are also freezable, though the process involves notifying the registrar as well as the court. Bank account balances are the most valuable asset class for creditors but also the hardest to identify without prior disclosure; the practical approach is to lead with real property and corporate assets in the interim application and to pursue account disclosure through the enforcement proceedings.

Q: What is the risk that Russian interim measures will be challenged or lifted by the respondent?

A: Russian procedure gives the respondent the right to apply to lift or vary an arest, and in practice respondents do challenge interim measures, sometimes successfully. The most common grounds for challenge are that the applicant has failed to establish a credible underlying claim, that the risk of dissipation has been overstated or is not evidenced, or that the value of frozen assets disproportionately exceeds the claimed debt. A well-prepared initial application — with solid evidence of the claim, documented evidence of dissipation risk, and a proportionate asset identification — substantially reduces the risk of a successful lift application. Counter-security provided by the applicant also reduces the court's receptiveness to lift applications based on disproportionality arguments.

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

The firm's asset tracing and recovery practice advises foreign trade creditors, institutional investors, and distressed debt holders on the preservation and recovery of Russian-situated assets. This includes coordinating interim measures before Russian arbitrazh courts, supporting worldwide freezing order applications with Russian-law intelligence, and acting as local counsel in cross-border enforcement mandates. With over 1,000 matters handled since inception, the team brings direct partner involvement to every engagement — no matter is delegated below the level of the supervising lawyer named on the instruction.

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/

In the years this firm has spent advising foreign creditors on Russian asset recovery, one pattern has become structurally significant: creditors who hold legitimate claims against Russian counterparties frequently discover that their own regulatory environment — specifically, OFAC sanctions — constrains how, when, and through what channels they may pursue enforcement. The result is a creditor caught between two legal orders: one demanding payment and granting access to Russian courts to obtain it, the other restricting the very steps required to do so. Understanding how those two orders interact, where they conflict, and where they leave workable space is now a foundational requirement for any foreign creditor with Russian asset recovery objectives.

For a foreign creditor holding a debt obligation against a Russian entity, the instinct is to move directly to enforcement: obtain a judgment or arbitral award, apply to the relevant Russian court for recognition, and pursue the debtor's Russian assets through established insolvency or execution channels. Under Russian civil procedure and insolvency legislation, those channels are well-defined. Russian arbitrazh courts process creditor applications to participate in insolvency proceedings, and general execution procedure provides routes to levy on bank accounts, moveable property, and registered assets held within the Russian Federation.

The difficulty arises the moment the creditor — or its bank, correspondent bank, or legal counsel — is subject to OFAC jurisdiction. OFAC's regulatory framework extends, as a matter of US law, to US persons and, under certain designations, to non-US entities conducting transactions that clear through the US financial system or involve US-origin goods and services. For creditors organised in the United States, or for those whose enforcement activities involve US-dollar transactions, the question is no longer purely whether Russian courts will enforce the claim. The question becomes whether the steps required to enforce it — retaining Russian counsel, paying court fees in Russian currency, receiving proceeds of enforcement — are themselves authorised under the applicable sanctions framework.

This is not a theoretical concern. In practice, creditors pursuing distressed assets in Russia have encountered compliance objections at each stage of the enforcement chain: at the level of retaining local counsel (where US-based firms may face restrictions on providing legal services to designated parties or in designated sectors), at the level of transacting with Russian financial institutions to move enforcement proceeds, and at the level of receiving those proceeds through correspondent banking channels that are subject to OFAC screening.

If you are a foreign creditor assessing whether your enforcement steps are structurally viable under both Russian law and your applicable sanctions framework — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The answer turns on three variables: the designation status of the debtor, the designation status of the creditor, and the category of the asset in question.

Where the Russian debtor is not itself a designated person or entity, and the creditor is similarly undesignated, the OFAC intersection is narrower. The primary concern in that configuration is transactional: ensuring that the enforcement steps — payments, receipts, and transfers — do not themselves constitute prohibited transactions under the sanctions programmes in force. OFAC general licences, which have at various points authorised certain transactions related to the maintenance and wind-down of pre-existing business relationships with Russia-connected counterparties, may provide a pathway, but their scope, duration, and renewal status require careful verification at each stage of enforcement. Creditors routinely underestimate the gap between a general licence authorising a class of transactions and the specific enforcement steps they wish to take.

Where the debtor is a designated entity — listed under OFAC's sectoral or blocking sanctions programmes — the position is considerably more restrictive. Blocked assets are, as a matter of US sanctions law, frozen in place: they cannot be transferred, paid, exported, withdrawn, or otherwise dealt in by US persons without a specific licence. A creditor subject to OFAC jurisdiction cannot, absent such a licence, receive enforcement proceeds that derive from a blocked account or blocked property, even where a Russian court has ordered payment. The Russian court order does not dissolve the OFAC block; the two legal regimes operate in parallel, and compliance with one does not authorise non-compliance with the other.

The asset categories that remain most practically accessible, subject to the above qualification, are those that are not themselves blocked under any applicable designation — receivables owed to the debtor by third-party Russian entities that are themselves undesignated, intellectual property rights registered in Russia and enforceable through the IP Court, and physical assets in Russia not captured by sector-specific restrictions. Our Asset Tracing & Recovery practice maps these categories at the outset of every creditor mandate, before enforcement steps are commenced.

Russian arbitrazh courts and courts of general jurisdiction do not, as a matter of their own procedural rules, give direct legal effect to foreign sanctions frameworks. A creditor whose enforcement is delayed or structurally impaired by OFAC restrictions cannot present that fact to a Russian court as a procedural justification for a stay, an extension of a limitation period, or a modification of the enforcement sequence. Russian civil procedure is self-contained in this respect: the clock on limitation periods runs under Russian law, and force majeure arguments based on foreign regulatory constraints have met with limited and inconsistent success before Russian tribunals.

This asymmetry creates a specific risk for creditors operating under sanctions constraints: the time required to obtain an OFAC specific licence — which in practice can extend to several months, and in complex cases longer — may erode the creditor's procedural position under Russian law. Creditors who delay initiating enforcement proceedings while awaiting OFAC clearance risk losing priority in an insolvency that the debtor may file unilaterally, potentially in a jurisdiction where the automatic stay provisions of Russian insolvency legislation will freeze the creditor's ability to take independent enforcement steps. This is the most acute version of the structural problem described in § I, and it is the scenario that, in our experience advising creditors on distressed assets in Russia, causes the greatest irreversible harm.

Practical experience with Russian courts also suggests that the debtor's counsel may raise sanctions-related arguments — not to give effect to the foreign regulatory constraint, but to introduce procedural complexity, delay enforcement hearings, or create grounds for appeal. These tactics are distinct from any genuine legal application of the sanctions framework by the Russian tribunal, but they are a real feature of contested enforcement proceedings that creditors should anticipate and prepare for.

"The OFAC intersection does not neutralise a creditor's Russian law claims — but it restructures the enforcement timeline in ways that Russian courts will not accommodate, which makes early parallel planning the only viable approach." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For creditors whose matter involves intellectual property assets or registered rights in Russia, the procedural dynamics differ somewhat — the IP Court's enforcement calendar and the specific enforcement mechanisms for registered rights create a different timeline structure. See our related analysis at Federal Tax Service guidance on OFAC-connected matters for the regulatory dimension, and our parallel briefing on OFAC sanctions intersection with Russian asset recovery — practitioner briefing for the procedural overlay.

For creditors who have a Russian court judgment or arbitral award but face sanctions constraints on receipt of enforcement proceeds — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The direct answer is that OFAC and Russian court enforcement mechanisms operate on different planes and do not formally override each other. OFAC does not instruct Russian courts; Russian courts do not defer to OFAC designations. What OFAC does is constrain the behaviour of persons subject to US jurisdiction — and for those persons, the practical effect of that constraint on a Russian enforcement programme can be functionally equivalent to a stay, even where no Russian court has ordered one.

The relevant question for a foreign creditor is therefore not whether OFAC overrides Russian enforcement, but whether the creditor can execute the enforcement steps that Russian law permits without violating its own compliance obligations. That analysis has three components:

• The designation status of each counterparty and financial institution in the enforcement chain, verified against the current Specially Designated Nationals and Blocked Persons list and any applicable sector-specific restrictions.
• The scope of any applicable general licences, including their expiry dates, permitted transaction types, and any conditions that attach to their use.
• The availability of a specific licence, assessed against OFAC's stated licensing policy for the relevant sanctions programme and the creditor's specific factual circumstances.

Where a creditor's jurisdiction is outside the United States — for example, where the creditor is incorporated in Germany, the Netherlands, or another EU member state — the relevant constraint may be the EU's own autonomous sanctions regulations rather than OFAC. EU regulations in this space have their own architecture, their own list of designated persons, and their own licensing framework. The interaction between EU sanctions and Russian enforcement procedure is analytically parallel to the OFAC intersection but differs in specific technical details: the EU does not maintain a directly equivalent general licence structure, and the derogation mechanisms available under EU regulations operate differently. Creditors in this position should take specific advice from counsel qualified in both Russian law and the applicable EU member state's regulatory framework. For matters requiring cross-jurisdictional analysis, the firm collaborates with trusted counsel in the relevant jurisdiction — we are a Russian-qualified law firm and do not provide US or EU regulatory advice directly.

The Restructuring & Insolvency dimension intersects here for creditors pursuing Russian debtors in insolvency: the Russian insolvency administrator is not a person subject to OFAC jurisdiction, and in some configurations this creates a structural possibility for the administrator to take steps that the creditor itself cannot — though the proceeds of those steps may then become subject to the same constraints when transferred to the creditor. This is a nuanced area of the Russia law analysis for foreign clients that requires fact-specific assessment. See the Matters section for representative matters involving creditor-side insolvency enforcement in Russia.

The overriding practical principle for creditors at the OFAC–Russian enforcement intersection is that the two regulatory environments must be mapped simultaneously and from the earliest stage of the mandate. Sequential analysis — first obtaining a Russian judgment, then assessing the OFAC position — routinely produces a situation in which the creditor holds a valid and enforceable Russian judgment that it cannot act upon within its compliance constraints.

Four priority steps structure a defensible approach:

1. Designation and transaction screening at mandate outset. Before any enforcement step is taken, the debtor, its affiliates, its bank, and the proposed enforcement intermediaries should be screened against the current SDN list and applicable sector-specific designations. This is not a one-time exercise: designations change, and a counterparty that was undesignated at the start of enforcement proceedings may become designated before proceedings conclude.

1. Licence assessment and, where appropriate, application. Where the enforcement programme requires transactions that may be restricted, the creditor's US or EU sanctions counsel should assess whether an existing general licence covers the specific steps and, where it does not, whether a specific licence application is viable given OFAC's stated policy. The specific licence application process is time-consuming under Russian legal framework timelines, and creditors should factor in that the Russian enforcement clock does not pause during the application period.

1. Parallel Russian law preservation steps. While licence applications are in progress, Russian law preservation steps — filing proofs of debt in insolvency proceedings, registering claims before the relevant registry deadline, obtaining interim measures from Russian courts where available — should proceed to the extent they can be taken without themselves constituting prohibited transactions. In many configurations, these steps can be taken without triggering the transactional restrictions that apply at the receipt-of-proceeds stage.

1. Enforcement chain architecture. The structure of how enforcement proceeds will flow from the Russian debtor or estate to the foreign creditor requires advance design, not retrospective resolution. Where proceeds will transit Russian financial institutions, correspondent banking channels, and potentially currency control mechanisms under the Russian legal framework, the architecture must accommodate both the Russian regulatory requirements and the creditor's compliance constraints.

For creditors at the earlier stage of assessing whether distressed assets in Russia are worth pursuing given the OFAC overlay, the practical answer is often yes — but only with a recovery strategy that is designed around both legal orders from the outset. Recoveries achieved in the past several years in matters where the OFAC intersection was carefully managed demonstrate that the structural complexity is navigable, though it requires more deliberate sequencing than straightforward Russian enforcement.

If you are structuring or reviewing a Russian asset recovery programme and need Russian law analysis that accounts for your sanctions framework — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Federal Tax Service guidance on OFAC-connected enforcement matters
• OFAC sanctions intersection with Russian asset recovery — practitioner briefing
• Asset Tracing & Recovery practice overview

Q: What is the OFAC sanctions intersection with Russian asset recovery, and why does it matter for foreign creditors?

A: The OFAC sanctions intersection arises when a foreign creditor holding a claim against a Russian entity is itself subject to US sanctions jurisdiction — either because it is a US person or because its enforcement activities involve US-dollar transactions or US-regulated intermediaries. In that configuration, the enforcement steps that Russian law permits — filing claims, receiving proceeds, transacting with Russian financial institutions — may themselves constitute restricted or prohibited conduct under the applicable sanctions programme. The intersection matters because Russian courts do not give effect to foreign regulatory constraints: the limitation clock runs, insolvency deadlines apply, and the court will not extend procedural time because the creditor is awaiting OFAC clearance. Creditors who manage both legal orders simultaneously, from the outset of the recovery programme, are materially better positioned than those who treat the sanctions assessment as a secondary step.

Q: Can a creditor subject to OFAC restrictions still file a claim in Russian insolvency proceedings?

A: In many configurations, yes. Filing a proof of debt in Russian insolvency proceedings — registering the claim with the insolvency administrator and the relevant court within the applicable deadline — is a procedural step that does not, in itself, typically constitute a blocked transaction or a prohibited payment under OFAC regulations. The more restrictive point in the enforcement chain is the receipt of proceeds: if the insolvency estate includes blocked assets, the eventual distribution to a creditor subject to OFAC jurisdiction may require specific licence authorisation. Creditors should obtain sanctions counsel confirmation of the specific transactions involved before taking each step, and should not assume that because filing is permissible, receipt of distribution proceeds will be equally unrestricted. The distinction between taking procedural steps and receiving economic benefit is an important one in this context.

Q: Does it matter whether the Russian debtor is itself a designated person?

A: Yes, substantially. Where the Russian debtor is designated — listed on the SDN list or subject to blocking sanctions under a sectoral programme — the debtor's assets are, as a matter of US sanctions law, blocked in place and may not be transferred to or received by US persons without a specific OFAC licence. A Russian court order directing payment does not dissolve the OFAC block; the two regimes are legally independent. Where the debtor is undesignated, the restrictions are narrower and may be addressed through applicable general licences, though those licences require careful verification for scope and currency. The designation status of the debtor's bank, the enforcement intermediaries, and any co-debtors or guarantors also forms part of the screening analysis.

Q: How do Russian limitation periods interact with delays caused by sanctions compliance?

A: Russian civil procedure limitation periods run under Russian law and are not suspended by foreign regulatory constraints, including OFAC restrictions. A creditor who delays filing its claim or initiating enforcement proceedings because it is assessing its OFAC position, or awaiting a specific licence, does so at the risk of losing its Russian law claim entirely if the limitation period expires in the interim. Russian courts have not developed a consistent doctrine of equitable tolling or force majeure extension on grounds of foreign sanctions compliance. The practical consequence is that creditors should initiate the Russian law preservation steps — filing claims, obtaining interim measures, registering in insolvency proceedings — as early as the sanctions compliance analysis permits, without waiting for complete certainty on the receipts side of the enforcement programme.

Q: Is the position different for EU-based creditors compared to US-based creditors?

A: The analytical framework is broadly similar — a dual-track assessment of Russian enforcement steps and the applicable sanctions regulatory constraints — but the technical details differ. EU autonomous sanctions regulations have their own list of designated persons, their own category of restricted measures, and their own derogation and licensing architecture, which does not mirror OFAC's general licence system. EU-based creditors are not subject to OFAC as such (absent US nexus), but are subject to their own member state's implementing legislation and to EU regulations with direct effect. The intersection with Russian enforcement procedure presents parallel challenges: Russian courts do not defer to EU regulations any more than to OFAC, and the clock runs regardless. EU-based creditors should take advice from counsel with expertise in both Russian law and the relevant EU regulatory framework. Vetrov & Partners advises on the Russian law dimension and collaborates with trusted counsel in EU jurisdictions for the regulatory side.

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 distressed debt holders on enforcement against Russian-held assets — including asset identification, insolvency creditor participation, and enforcement proceedings before Russian arbitrazh courts. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with direct partner involvement on every engagement. Where cross-border regulatory analysis is required — including sanctions compliance — the firm collaborates with trusted counsel in the relevant jurisdiction.

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/

In three years of advising foreign creditors in Russian asset recovery matters, one pattern recurs with uncomfortable regularity: the assumption that cryptocurrency holdings are either untraceable or beyond the reach of formal enforcement. Neither is accurate under current Russian law – but the tools available to a creditor tracing digital assets against a Russian counterparty diverge in material and often frustrating ways from the standards that foreign practitioners take as a baseline. Russia now has a functioning statutory classification of digital assets, a growing body of court practice applying that classification to creditor claims, and a set of exchange-level cooperation mechanisms that – when deployed correctly – can yield recoverable value. What Russia does not yet have is a coherent tracing infrastructure that maps cleanly onto FATF Recommendation 15 or the travel-rule expectations embedded in EU and UK crypto-asset regulation. For the foreign creditor instructing Russian counsel, understanding that gap is the starting point for a realistic recovery strategy.

The foundational instrument is Federal Law No. 259-FZ on Digital Financial Assets (DFA), which came into force in January 2021 and has since been supplemented by amendments that extended its scope and clarified the treatment of foreign-issued digital rights. Under that framework, Russian law distinguishes between two categories: digital financial assets – a regulated instrument issued through an operator registered with the Bank of Russia – and other digital rights, a residual category that encompasses most internationally traded cryptocurrencies, including Bitcoin and Ether. The practical consequence for a creditor is that a counterparty holding Bitcoin does not hold a DFA in the Russian statutory sense; it holds a species of property that Russian civil law now recognises as an object of civil rights but that sits outside the DFA supervisory perimeter entirely.

Classification matters to traceability because the two categories attract different disclosure mechanisms. DFA issued through licensed operators are subject to Bank of Russia oversight and, in principle, to compelled disclosure orders directed at the operator. Other digital rights – the category into which most externally traded cryptocurrency falls – are subject only to the general civil procedure rules on evidence and to the limited framework that Russian courts have been developing through practice since 2019. A creditor tracing a counterparty's DFA holding has a relatively legible institutional route. A creditor tracing Bitcoin or stablecoin holdings that a counterparty has moved through a non-Russian exchange faces a materially more contested procedural environment. That distinction is insufficiently understood by foreign practitioners approaching a Russian tracing matter for the first time.

The EAEU dimension adds a further layer: Russia's membership of the Eurasian Economic Union means that assets held through entities in Kazakhstan, Belarus, or Armenia may be subject to parallel tracing avenues, particularly where those jurisdictions have concluded mutual legal assistance arrangements with Russia that cover civil as well as criminal proceedings.

For foreign creditors assessing whether digital assets held by a Russian counterparty are traceable and recoverable under current Russian law, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Russian courts have accepted cryptocurrency as an asset capable of being included in a debtor's estate since a series of significant decisions from 2019 onwards. The legal basis is the civil law recognition of digital rights as objects of civil rights under the Civil Code, read alongside the DFA Law and – in insolvency contexts – the amendments to the insolvency legislation that give a bankruptcy administrator authority to identify, preserve, and realise assets of the debtor including digital rights. For a foreign creditor participating in Russian insolvency proceedings, this means that cryptocurrency identified in the debtor's possession or traceable to addresses controlled by the debtor is, in principle, available for inclusion in the creditor claims register.

In practice, however, the tracing tools available within the domestic framework are narrower than their equivalents in major common law jurisdictions. Russian civil procedure does not provide an equivalent to the Norwich Pharmacal order or the Bankers Trust disclosure mechanism. The court may, on application, compel a party to disclose financial information or require a third party to produce documents, but the procedural standard for granting such an order is higher than in English practice and the enforcement of disclosure against non-resident exchanges operating without Russian registration is largely aspirational absent mutual legal assistance. What works in practice is a combination of: on-chain analysis conducted by a qualified forensic firm whose methodology Russian courts have accepted as expert evidence; disclosure applications directed at Russian-licensed or Russian-present entities (banks, licensed exchange operators, payment aggregators); and, in insolvency contexts, the broader investigative powers of the bankruptcy administrator under the insolvency legislation.

The Russian insolvency framework also provides the mechanism most frequently used in practice to reach digital assets held by corporate debtors. A bankruptcy administrator with court authority can seek to have cryptocurrency wallets identified as estate property and to compel the debtor's controlling persons to disclose wallet credentials or private keys. This is not a theoretical power – Russian courts have made orders requiring disclosure of wallet access credentials, and non-compliance has been treated as grounds for imposing subsidiary liability on controlling persons of the debtor. For distressed asset creditors entering a Russian insolvency, this procedural reality means that early engagement with the administrator on digital asset identification is strategically material. Creditors who delay risk losing priority in the distribution queue once assets have been realised.

The honest answer is that Russian law is directionally aligned with FATF Recommendation 15 in its formal classification of virtual asset service providers (VASPs) but remains at an early stage of implementing the operational requirements that make FATF-standard tracing practically functional for a foreign creditor. FATF's framework for digital asset tracing rests on three pillars: mandatory VASP registration, travel-rule compliance (the transmission of originator and beneficiary information alongside transfers above the threshold), and the capacity of financial intelligence units and creditor-side practitioners to compel disclosure from registered VASPs in response to properly formulated legal requests. Russia has made progress on the first pillar – the DFA Law and subsequent Bank of Russia guidance establish a VASP registration regime – but the travel rule has not been implemented in a form that creates a usable disclosure trail for civil creditors, and the Bank of Russia's financial intelligence interface is oriented towards criminal and regulatory proceedings rather than civil recovery.

"The core challenge for foreign creditors is not that Russian courts refuse to engage with cryptocurrency – they do engage, and increasingly so – but that the disclosure infrastructure a creditor needs to trace assets from an identified wallet back to a recoverable pool is still being built." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

Contrast this with the EU's Markets in Crypto-Assets Regulation (MiCA) framework or the UK's approach under the Financial Services and Markets Act 2023, both of which impose travel-rule obligations that generate a structured data trail accessible to creditors through court-ordered disclosure. Under those regimes, a creditor with a judgment or freezing order can follow a transfer through a regulated exchange with reasonable confidence that the exchange holds originator data. Under the current Russian framework, the same creditor faces a more granular forensic task: establishing wallet control through on-chain analysis, then constructing a procedural route to either the wallet-holder's identity or to the fiat off-ramp through which value was extracted.

The gap is not unbridgeable. Russian courts have shown increasing willingness to accept blockchain analytics reports as expert evidence, and the combination of on-chain forensics with targeted disclosure applications – particularly through insolvency proceedings where administrator powers are broadest – has produced creditor recoveries in practice. The limitation is that each step requires contested court proceedings rather than administrative disclosure, which extends timelines and increases costs in ways that the FATF standard was specifically designed to avoid.

Creditors tracing digital assets in Russian insolvency proceedings benefit from coordinating forensic analysis with procedural strategy from an early stage. Discuss your matter in confidence: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Foreign creditors frequently encounter a structural question: does a Russian court's tracing order have any operational reach outside Russia, and can a foreign court order be used to compel disclosure within Russia? The answers are, respectively, limited and contested. Russia is not party to a multilateral civil mutual legal assistance convention of the scope that would give a foreign disclosure order direct operational force in Russian proceedings. Bilateral treaties exist with a significant number of jurisdictions – including Germany, France, Italy, and several CIS members – but their application to digital asset disclosure specifically has not been tested comprehensively in reported cases, and the practical experience in the field is that MLA in civil matters moves slowly.

What has worked is a more indirect route: using Russian insolvency proceedings as the primary tracing forum, where the administrator's powers are broadest and where foreign creditors can participate as registered creditors with standing to make applications. The Asset Tracing & Recovery practice at Vetrov & Partners has coordinated this approach in matters involving offshore asset structures where a Russian operating entity was placed into insolvency while related-party transfers had moved value into cryptocurrency wallets prior to the filing. The relevant jurisprudence on challenging such transfers as preferential or deliberate asset-stripping transactions is developing rapidly – the Russian Supreme Court's clarification on digital asset recovery has been particularly significant in consolidating the basis for administrator challenges in insolvency.

For cross-border matters where the counterparty has used a non-Russian exchange to off-ramp value, the practical tracing route typically involves instructing a blockchain analytics firm with Russian court-admissible methodology, using the on-chain trail to identify the receiving exchange, and then pursuing disclosure through whatever jurisdiction governs that exchange. A Cayman or BVI-registered exchange may be subject to compelled disclosure through English or US proceedings more readily than through a Russian court order. This multi-jurisdictional sequencing – Russian proceedings to establish wallet control, foreign proceedings to compel exchange disclosure – is the operative architecture for serious cross-border digital asset recovery matters. The Restructuring & Insolvency dimension matters here because the timing of insolvency proceedings relative to the transfer dates determines which challenge mechanisms are available.

For practitioners seeking a more detailed procedural map of this framework, the guide to navigating digital asset and cryptocurrency tracing in Russian proceedings sets out the step-by-step approach in practice context, including documentation requirements and timeline expectations.

Creditors who believe a Russian counterparty has placed value into cryptocurrency before or after a default should take five practical steps as early as possible. First, commission blockchain analytics before initiating proceedings. On-chain analysis can identify wallet clusters associated with known exchange deposits, cross-referencing with publicly available address attribution data. This evidence – if produced by a firm whose methodology has been accepted by Russian courts – provides the foundation for all subsequent procedural steps. Commissioning it late, after proceedings have commenced, gives the counterparty's controlling persons time to fragment wallets and complicate attribution.

Second, assess whether insolvency proceedings are available and advantageous. The administrator's powers in Russian bankruptcy are the most effective domestic tool for compelled digital asset disclosure. If the debtor is insolvent or likely to become so, a creditor-initiated insolvency application – filed strategically with regard to the pre-insolvency transfer window – can unlock investigative powers that are unavailable in ordinary civil proceedings. Under Russian insolvency legislation, preferential transfers completed within certain periods before the bankruptcy filing may be challenged and reversed, a window that creditors unfamiliar with Russian law frequently underestimate. Early action preserves the ability to bring those challenges; delay may not.

Third, identify the fiat off-ramp jurisdiction. Cryptocurrency must be converted to fiat currency through an exchange or OTC desk at some point if it is to be practically useful to a counterparty. The exchange jurisdiction determines which legal system governs the most critical disclosure point in the chain. Identifying that jurisdiction early allows parallel proceedings to be structured correctly.

Fourth, consider EAEU-member jurisdiction angles. Where value has moved through entities in Kazakhstan or Belarus – both FATF members with evolving crypto-asset regulatory frameworks – the bilateral civil cooperation mechanisms between those jurisdictions and Russia may provide a faster route to disclosure than attempting to enforce a Russian order against a non-resident exchange.

Fifth, co-ordinate with Russian counsel from the outset. Digital asset tracing in Russian proceedings requires simultaneous management of the forensic evidence, the civil or insolvency procedure, and the regulatory disclosure mechanisms that the Bank of Russia's VASP framework provides. Foreign law firms seeking local counsel for this type of matter will find that the procedural and evidential requirements are sufficiently distinct from common law tracing practice that early instruction of specialist Russian counsel – rather than instruction at the point when a court application has already been filed – is consistently the better approach. See the Matters Hub for representative engagements of this type.

If you are a foreign creditor with a Russian counterparty and have reason to believe digital assets have been used to move or conceal value, our asset tracing team can assess your recovery options. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Russian Supreme Court clarification on digital asset recovery in insolvency
• Navigating digital asset and cryptocurrency tracing in Russian proceedings: a practitioner's guide
• Asset Tracing & Recovery practice

Q: Can a foreign creditor obtain a court order in Russia compelling a counterparty to disclose cryptocurrency wallet addresses or private keys?

A: Russian courts have made orders requiring disclosure of wallet credentials and private keys, most commonly in insolvency proceedings where the bankruptcy administrator makes the application on behalf of the creditor body. In ordinary civil proceedings, the procedural threshold for compelling a party to produce this information is higher, and the mechanism is less reliably available. The most effective route for a foreign creditor is to pursue wallet disclosure through insolvency proceedings rather than as a standalone civil application. Courts have treated non-compliance with disclosure orders in insolvency as a basis for imposing subsidiary liability on the debtor's controlling persons, which provides a meaningful enforcement lever.

Q: Does Russia apply the FATF travel rule in a way that foreign creditors can use to trace transfers between exchanges?

A: Not yet in a form that is directly useful to civil creditors. Russia's virtual asset service provider registration framework – established under the Digital Financial Assets Law and Bank of Russia guidance – is formally aligned with FATF Recommendation 15, but the travel rule's originator-and-beneficiary data requirements have not been implemented in a way that creates a structured disclosure trail accessible to creditors through civil proceedings. In practice, creditors rely on on-chain forensic analysis rather than regulatory data from VASP compliance records. This differs materially from the position under EU MiCA or UK financial services regulation, where travel-rule data can be compelled through court-ordered exchange disclosure.

Q: What is the limitation period for challenging transfers of cryptocurrency as fraudulent or preferential under Russian insolvency law?

A: Russian insolvency legislation provides tiered challenge windows for pre-insolvency transfers. Transactions completed within a shorter period before the bankruptcy filing can be challenged as preferential where the creditor received disproportionate benefit relative to other creditors. Transactions that were made with deliberate intent to harm creditors, which includes transfers of value – including digital assets – to related parties at undervalue, carry a longer challenge window. The precise periods are set by the insolvency legislation and their calculation depends on when the bankruptcy application is deemed filed, not when proceedings were formally opened. Because the window begins running from the filing date, the timing of a creditor's insolvency application relative to suspected transfers is strategically significant. We advise creditors to obtain a limitation analysis before deciding whether and when to file.

Q: Is cryptocurrency held in a foreign exchange wallet subject to Russian enforcement proceedings?

A: The short answer is that the Russian court can make an order establishing that the wallet constitutes estate property, but enforcement of that order against a non-resident exchange involves the jurisdiction governing the exchange rather than Russian law. In practice, a Russian insolvency administrator's power to access wallet contents depends on either obtaining the private key through the debtor's cooperation or a disclosure order, or on coordinating with foreign proceedings in the jurisdiction where the exchange is registered. Multi-jurisdictional enforcement of this nature is feasible but requires parallel proceedings rather than a single Russian court order.

Q: How do EAEU membership and CIS conventions affect cross-border digital asset tracing involving Russian counterparties?

A: Russia's membership of the Eurasian Economic Union and its participation in CIS civil cooperation conventions create potential channels for cross-border tracing that are faster than general multilateral routes. In particular, bilateral civil MLA arrangements with Kazakhstan – which has an advanced crypto-asset regulatory framework of its own, including a functioning VASP registration regime at the Astana International Financial Centre – can be productive where value has been moved through Kazakh entities or exchanges. Belarus similarly sits within the bilateral MLA perimeter. The practical availability of these routes depends on the specific transfer pattern, the entities involved, and the current state of cooperation between the relevant judicial or regulatory bodies. A preliminary assessment of which jurisdictions are involved in the asset trail is the necessary first step before selecting a cross-border procedural strategy.

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 and recovery practice advises foreign creditors, institutional investors, and cross-border claimants on the identification, preservation, and realisation of Russian-sited assets. The practice combines on-chain forensic coordination with procedural strategy across Russian civil, insolvency, and regulatory forums. With over 1,000 matters handled since inception, the team brings direct partner and senior-lawyer involvement to every engagement, without delegation to more junior fee-earners.

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/

When a foreign creditor moves to enforce against a Russian counterparty and discovers that the company's registered shareholders are holding vehicles – nominees, intermediate Cyprus or UAE entities, or cascaded Russian limited liability companies – the practical consequence is not merely inconvenience. In many cases it is a material barrier to recovery. Russian law has, over the past decade, constructed an increasingly detailed framework of beneficial ownership disclosure obligations applicable to legal entities operating in Russia. Yet that framework is uneven in its application, inconsistently enforced, and contains structural gaps that sophisticated debtors can and do exploit. For foreign creditors and distressed investors tracing assets through Russian corporate chains, understanding what the law requires – and where it falls short – is the starting point for any effective enforcement strategy.

The Russian beneficial ownership disclosure regime operates through two principal channels: statutory obligations imposed on legal entities to identify and record their beneficial owners, and state register and reporting requirements under anti-money laundering legislation and tax transparency rules.

Under Russian anti-money laundering legislation, most legal entities incorporated in Russia are required to identify their beneficial owners – defined as natural persons who ultimately own or control the entity – and to maintain this information in internal records. Entities are also required to update this information when it changes and, on request, to disclose it to authorised state bodies. The threshold for beneficial ownership generally tracks the internationally recognised standard: a natural person holding, directly or indirectly, more than twenty-five per cent of shares or voting rights, or otherwise exercising effective control.

The tax transparency dimension adds a further layer. Russian controlled foreign company rules and transfer pricing regulations impose disclosure obligations on Russian tax residents who hold interests in foreign structures, and these rules have been progressively tightened since 2015. For foreign creditors, the significance lies in the fact that Russian counterparties with foreign ownership layers are in principle required to disclose the identity of their ultimate beneficiaries to the Federal Tax Service – a disclosure that, if it has been made, creates a document trail available to creditors through ancillary proceedings.

Corporate registry obligations, governed by civil and corporate legislation, require that information on shareholders of record be maintained and, for joint-stock companies, be reflected in the shareholder register. Limited liability companies must maintain a participants' list. Neither requirement, however, directly mandates disclosure of the ultimate natural person behind a corporate shareholder chain. This is the central structural gap: the publicly accessible corporate register discloses legal ownership one layer deep, not beneficial ownership in its substantive sense.

For foreign creditors seeking to map beneficial ownership in advance of enforcement – make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The beneficial ownership disclosure obligations under anti-money laundering legislation apply broadly to Russian legal entities, including limited liability companies, joint-stock companies, and production cooperatives. Certain categories are treated as lower-risk and may benefit from simplified identification requirements: companies whose shares are publicly traded on a Russian exchange, state-owned enterprises, and international organisations are examples where the rules operate differently in practice.

The more significant gaps arise at the intersection of form and substance. A Russian operating company may be wholly owned by a foreign holding company registered in a jurisdiction with its own beneficial ownership regime – or, increasingly, in a jurisdiction whose information-sharing arrangements with Russia have been materially disrupted. Where the intermediate holding layer is a company registered in a jurisdiction that does not exchange ownership information with Russia through any current treaty or administrative channel, the Russian operating company may in practice be unable to identify its own ultimate beneficial owner with any certainty. The law does not excuse non-disclosure in these circumstances, but enforcement of the internal record-keeping obligation against such a company is administratively complex and rarely pursued as a standalone matter.

A further gap concerns nominees. Russian law does not prohibit nominee arrangements outright, but it does require that nominees acting as participants or shareholders in a Russian entity be identified as such, and that the identity of the nominator be disclosed in the entity's internal beneficial ownership records. In practice, this requirement is frequently honoured in the breach. Nominee arrangements are often documented only in private agreements governed by foreign law, which are not reflected in any Russian-accessible register. The recent legislative amendments affecting beneficial ownership obligations – analysed in detail in our separate note at Legislative Amendment Affecting Beneficial Ownership – have addressed some of these gaps, but the implementation gap between statutory obligation and administrative enforcement remains material.

For creditors, the implication is that the absence of recorded beneficial ownership information in a Russian entity's internal registers does not mean the entity is compliant with a theoretical standard of full transparency. It may equally mean that the entity has failed to maintain records as required – a failure that, in proceedings, can become relevant to questions of corporate veil piercing and officer liability.

Opacity in beneficial ownership is not merely an information problem. For a foreign creditor seeking to enforce a claim against a Russian counterparty, it generates a series of compounding practical difficulties that affect each stage of the enforcement process.

At the pre-claim stage, the creditor's ability to identify enforcement targets – and to assess whether those targets hold recoverable assets – depends heavily on the accuracy of ownership information. If the registered owner of real property, machinery, or a bank account is a Russian shell company whose ultimate owner is unknown, the creditor cannot easily assess whether an insolvency application, a claim for enforcement of a foreign arbitral award, or a domestic court claim will yield a meaningful recovery. The risk of expending legal costs on proceedings against a structurally asset-stripped entity is material, and it is a risk that foreign creditors unfamiliar with the Russian legal framework for beneficial ownership disclosure consistently underestimate.

"The most consequential ownership opacity cases we encounter are not those involving elaborate offshore structures – they are those involving straightforward intermediate holding companies that have simply never been asked to identify their ultimate owner by any competent authority." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement & Asset Protection, Vetrov & Partners

At the claim stage, the inability to identify the beneficial owner constrains the creditor's options for cross-claims, third-party liability, and subsidiary enforcement routes. Under Russian insolvency law, the ability to bring controlling person liability claims – claims against those who actually directed the insolvent entity – depends in part on demonstrating who exercised beneficial control. A creditor without beneficial ownership information is materially disadvantaged in building a controlling person liability case. This is one area where the disclosure framework, however imperfect, intersects directly with creditor-side recovery strategy: any document the debtor entity was required to maintain under anti-money laundering legislation, but failed to maintain, becomes potentially relevant to an inference of deliberate concealment. Russian courts have, in a line of cases following amendments to insolvency legislation, been willing to draw adverse inferences from a debtor's failure to maintain or produce required corporate records.

Foreign creditors who delay initiating enforcement proceedings while attempting to map ownership structures without professional assistance risk losing priority in an insolvency that may be filed unilaterally by the debtor once it becomes clear that a creditor is active. Under Russian insolvency legislation, preferential transfer claims and the window for challenging pre-insolvency asset disposals are time-limited, and the window begins running from the date of the challenged transaction – not from the date the creditor discovers it.

If opacity in your counterparty's ownership structure is creating uncertainty about enforcement strategy – request our practice review: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

For foreign creditors, the interaction between Russian beneficial ownership disclosure rules and the cross-border enforcement landscape introduces additional strategic considerations.

Where a foreign creditor holds a foreign arbitral award or a foreign court judgment and seeks recognition and enforcement in Russia, the question of beneficial ownership information arises in a different register. The Russian respondent's ownership structure may be relevant to identifying which Russian court has territorial jurisdiction over enforcement proceedings, which assets are nominally held by the award debtor as distinct from related entities, and whether interim relief – including an attachment order – can be obtained over assets held through intermediate structures. Enforcement through Russian state courts requires precise identification of the enforcement debtor and the assets subject to execution. A foreign arbitral award naming a parent company does not automatically extend to assets held by a Russian subsidiary, even where the subsidiary is wholly owned by the award debtor. The beneficial ownership disclosure framework, perversely, can assist the creditor here: to the extent that the Russian subsidiary has disclosed its beneficial owner – whether in state reporting or in the course of financial account opening – that disclosure creates a documentary basis for the creditor's argument that the parent and subsidiary should be treated as a unified enforcement target in the appropriate Russian procedural context.

The tax transparency dimension is also potentially useful for creditors. The Federal Tax Service holds beneficial ownership and controlled foreign company declarations filed by Russian tax residents. This information is not publicly accessible, but it may be obtainable through court-ordered disclosure in the context of enforcement or insolvency proceedings. Foreign creditors – particularly those already engaged in Russian litigation or insolvency proceedings – should consider whether their Russian counsel can formulate requests for judicial assistance directed at obtaining tax authority records, within the procedural constraints that apply to such applications.

EAEU membership context warrants a brief note. For counterparties with business operations across EAEU member states – Belarus, Kazakhstan, Armenia, Kyrgyzstan – the beneficial ownership disclosure landscape is not uniform. Each jurisdiction has its own anti-money laundering and corporate transparency framework, and the level of practical enforcement varies. A Russian operating company with an intermediate Kazakh or Belarusian holding layer will be subject to the disclosure requirements of both jurisdictions, but the practical availability of information in the intermediate jurisdiction may be lower than in Russia. Cross-border asset tracing in the EAEU context therefore requires a jurisdiction-specific analysis of each layer in the ownership chain.

The firm's broader analysis of the disclosure obligations framework applicable to Russian and EAEU-connected structures is set out in our note on Beneficial Ownership Disclosure Obligations – which addresses the substantive legal obligations across the most common cross-border ownership configurations.

For in-house counsel managing a Russian counterparty relationship, or for distressed investors considering acquisition of claims against a Russian obligor, understanding the information that was and was not disclosed to Russian authorities at each level of the ownership chain is a material input into any recovery assessment.

The starting point for any creditor facing beneficial ownership opacity in a Russian enforcement context is a structured information audit: a systematic review of what ownership information is available in public registers, what can be inferred from financial and corporate filings, and what the counterparty was legally required to disclose but may have failed to maintain.

Russian public registers – the unified state legal entities register (EGRUL), Rosreestr for real property, and court database systems – contain information that, taken together, can establish one to two layers of corporate ownership and significant asset positions. This is rarely sufficient on its own, but it establishes a baseline against which gaps in the ownership chain can be identified precisely. Identifying the specific layer at which beneficial ownership information becomes unavailable is more useful than a general conclusion that the structure is opaque.

Where internal records should exist – because the Russian entity is subject to the anti-money laundering beneficial ownership record-keeping obligation – but have not been produced, that failure can be raised in the context of enforcement or insolvency proceedings. Courts in the Siberian and Ural federal districts, where a significant portion of industrial and natural-resource-connected enforcement matters arise, have demonstrated willingness to treat unexplained gaps in corporate record-keeping as relevant to creditor-side applications for disclosure and to controlling person liability claims.

Foreign creditors considering assignment or acquisition of distressed claims against Russian obligors should request, as part of their due diligence, a disclosure audit confirming what beneficial ownership information the target entity has on file – and what it was required to have on file. The gap between the two is often more informative than the records themselves. This dimension of distressed asset due diligence is addressed in detail in our Asset Tracing & Recovery practice overview.

For advisers instructing Russian counsel on enforcement matters, the practical recommendation is to engage before the insolvency filing rather than after it. Once Russian insolvency proceedings are under way, access to the debtor's internal records – including beneficial ownership records – becomes subject to the insolvency administrator's control. A foreign creditor who has not established its claim and its asset-mapping position before the insolvency petition is filed will find the information environment materially more constrained.

For in-house counsel or distressed investors seeking to assess enforcement prospects against a Russian counterparty – make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Legislative Amendment Affecting Beneficial Ownership — What Changed for Russian Entities
• Beneficial Ownership Disclosure Obligations Under Russian Law — A Practitioner Overview
• Asset Tracing & Recovery Practice — Vetrov & Partners

Q: What does Russian law require a legal entity to disclose about its beneficial owners?

A: Under Russian anti-money laundering legislation, most Russian legal entities must identify the natural persons who ultimately own or control them – generally defined as those holding more than twenty-five per cent of shares or voting rights or otherwise exercising effective control – and maintain this information in internal records. Entities must update these records when ownership changes and produce them on request to authorised state bodies, including the Federal Tax Service and financial monitoring authorities. The obligation extends to identifying nominees acting as shareholders or participants and recording the identity of the nominator. Non-compliance does not automatically void the entity's acts, but it exposes the company and its officers to administrative liability and, in enforcement or insolvency proceedings, can support adverse inferences about the deliberate concealment of control.

Q: Can a foreign creditor access beneficial ownership records held by a Russian counterparty in enforcement proceedings?

A: Direct access to a Russian counterparty's internal beneficial ownership records is not available to a foreign creditor outside of formal proceedings. Within Russian court proceedings – whether enforcement of a foreign arbitral award, a domestic civil claim, or insolvency proceedings – a creditor may apply for judicial assistance in compelling disclosure of relevant corporate records, including beneficial ownership registers. The procedural basis for such applications exists under Russian civil and arbitrazh procedure rules, but the outcome depends on the specific court, the evidentiary framing of the request, and whether the records in question are within the debtor's custody and control. In insolvency proceedings, the insolvency administrator has direct access to the debtor's records; a creditor with a recognised claim can request that the administrator investigate and report on ownership structures.

Q: Does EAEU membership affect the beneficial ownership disclosure position of Russian-connected structures?

A: EAEU membership does not create a unified beneficial ownership disclosure regime across the bloc. Each member state – Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan – maintains its own anti-money laundering and corporate transparency framework. The standards broadly follow FATF recommendations, but implementation and practical enforcement vary materially between jurisdictions. For a Russian operating company with a Kazakh or Belarusian intermediate holding entity, the beneficial ownership disclosure obligations in each jurisdiction apply independently, and the information available in the intermediate jurisdiction's registers may be substantially less complete than what Russian law requires at the Russian entity level. Cross-border creditors should therefore conduct a jurisdiction-specific analysis at each holding layer rather than assuming that Russian disclosure standards apply across the entire structure.

Q: What is the significance of the twenty-five per cent ownership threshold in the Russian beneficial ownership framework?

A: The twenty-five per cent threshold functions as a rebuttable presumption: a natural person holding more than twenty-five per cent of shares or voting rights is presumed to be a beneficial owner. However, the definition is not limited to shareholding. A person who exercises effective control over the entity's decisions – regardless of their registered ownership percentage – may also fall within the beneficial owner definition. For enforcement purposes, this means that creditors should not treat a structure in which no single shareholder exceeds twenty-five per cent as exempt from beneficial ownership analysis. The control test, which looks at actual decision-making authority, is the substantive standard; the ownership threshold is the administrative trigger for mandatory identification.

Q: How do Russian courts approach cases where a debtor has failed to maintain required beneficial ownership records?

A: Russian courts, particularly in insolvency-related proceedings, have developed a practice of treating a debtor's failure to maintain required corporate records – including beneficial ownership registers – as relevant to applications by creditors and insolvency administrators for controlling person liability. Where a debtor company cannot produce records it was legally obliged to keep, courts have in a number of cases been willing to place the burden on the debtor or its former directors to explain the gap. This does not automatically establish liability, but it materially shifts the evidentiary position and strengthens creditor-side arguments for disclosure orders and for holding former management accountable for the debtor's obligations. The specific procedural context – pre-insolvency enforcement proceedings versus insolvency administration – affects the precise legal route available to the creditor.

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, distressed investors, and their counsel on ownership mapping, enforcement strategy, and claim recovery against Russian obligors. The practice combines procedural depth in Russian state court and insolvency proceedings with experience in the cross-border information-gathering that complex recovery mandates require. 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 & Asset Protection, Vetrov & Partners vetrovpartners.com/razina/

When a foreign creditor discovers that the Russian debtor company it is pursuing holds no meaningful assets in its own name, the investigation rarely ends there. Nominee arrangements — structures in which formal legal title to shares, real property, or operating assets is held by one party while the economic interest belongs to another — are a documented feature of Russian asset structuring practice. For creditors seeking recovery, these arrangements present some of the most technically demanding challenges in Russian enforcement: the nominee holder may be genuinely judgment-proof, the beneficial owner may be difficult to identify, and the transactions creating the arrangement may have been carefully documented to appear arm's-length. This analysis examines how nominee arrangement risks arise in Russian practice, what legal tools are available for creditors, and how Russian courts have approached the unwinding of nominee structures in enforcement and insolvency proceedings.

Under Russian civil legislation, a nominee arrangement in its most common form involves a separation between formal legal ownership and economic beneficial interest. The nominee holder — often a natural person or a shell company — appears on the register of shareholders, the land register, or the corporate record as the owner. The beneficial owner retains actual control, receives economic benefits, and frequently retains an undated transfer document or power of attorney enabling reversion on demand.

Russian law does not use the term "nominee" as a statutory category. Instead, Russian courts analyse nominee arrangements through the lens of two well-established civil law concepts: the sham transaction (притворная сделка) and the simulated transaction (мнимая сделка). A sham transaction is one that conceals a different transaction the parties actually intended; a simulated transaction is one entered into with no genuine intention of creating legal consequences. Both types are void under Russian civil legislation, and courts may apply these concepts to the underlying transfer of legal title if the creditor can demonstrate that the parties' actual intent differed from the formal documentation.

Beyond the civil law concepts, Russian legislation on beneficial ownership disclosure has introduced additional mechanisms. Since 2017, a framework has required legal entities to identify and record their ultimate beneficial owners (UBO) and to disclose that information to authorised bodies upon request. While enforcement of this framework has been uneven in practice, the legislative record it creates can be significant in enforcement proceedings: a company that has internally recorded a beneficial owner different from the registered shareholder has, in effect, acknowledged the nominee character of the formal title.

For a foreign creditor pursuing asset recovery in Russia, nominee arrangement risks operate on several levels simultaneously. The most immediate risk is visible asset depletion: when enforcement proceedings begin — or, in some cases, before they begin — assets recorded in the debtor's name may be transferred to nominees, leaving the debtor formally balance-sheet-insolvent while the economic value of the business remains intact and controlled.

The timing risk is particularly acute. Under Russian insolvency legislation, transactions that transfer assets at undervalue, transactions that prefer one creditor over others, and transactions that harm the general body of creditors may be challenged as void — but only within defined look-back windows. For transactions with related parties or transactions that transferred assets for no consideration, courts have applied look-back periods of up to three years before the date of the insolvency filing. A foreign creditor that delays initiating enforcement or insolvency proceedings forfeits the practical ability to challenge transfers that fall outside that window, even where the nominee character of those transfers is apparent. This is not a theoretical risk: in several matters handled by the firm across the Siberian Federal District, the difference between a timely insolvency filing and a delayed one has determined whether an entire category of pre-transfer assets remained within reach of creditor challenge.

A secondary risk involves third-party nominee holders who acquire formal title for value and without notice of the beneficial ownership arrangement. Russian civil law provides protection for good-faith purchasers in certain circumstances, and while courts have been willing to pierce nominee arrangements when the nominee holder is a connected party or a shell with no independent economic activity, a genuine third-party transferee for value may be insulated from unwinding claims. Creditors must therefore act promptly once nominee arrangements are identified — both to preserve the look-back window and to prevent further disposal of assets through the nominee chain.

If you are a foreign creditor dealing with a Russian debtor whose assets appear to be held through nominee arrangements, the recovery window is time-sensitive. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The unwinding of a nominee arrangement in Russian court proceedings draws on a toolkit that has been developed across commercial arbitrazh courts over many years. The principal mechanisms are: (1) challenge of the underlying transfer as a sham or simulated transaction; (2) challenge under insolvency avoidance provisions; (3) claims for unjust enrichment against the nominee holder; and (4) corporate-law mechanisms for restoring registered title. In practice, these routes are frequently combined.

The sham-transaction route requires the creditor — or, in insolvency proceedings, the insolvency administrator acting on behalf of creditors — to demonstrate that the formal documentation of the transfer does not reflect the parties' actual agreement. Evidence courts have admitted in this context includes: the continued physical possession of assets by the transferor after the formal transfer; the absence of a market-rate payment; the retention of control over the management of the transferred business; internal correspondence or accounting records that treat the transferred asset as belonging to the transferor; and the absence of any commercial rationale for the transfer from the perspective of the nominee.

Insolvency avoidance provisions operate differently. Here, the creditor does not need to prove that the original parties had a hidden intent; the transaction is voidable if it satisfies the statutory criteria — transfer at an undervalue, preference of a connected creditor, or harm to the general body of creditors. The standard of proof is lower, but the look-back window is fixed, and the transaction must qualify under the specific statutory ground relied upon.

"Nominee arrangements present enforcement counsel with a structural paradox: the same documentation that made the arrangement seem legitimate at inception frequently provides the most powerful evidence for unwinding it in court proceedings — the absence of any genuine economic rationale is often self-evident from the record."

— Elizaveta Razina, Senior Lawyer, Practice Lead — Asset Tracing & Recovery, Vetrov & Partners

Courts across the arbitrazh system — including at the cassation level — have accepted that nominee arrangements of sufficient clarity may be unwound even in the absence of formal confessions or internal memoranda acknowledging the nominee character of the title. The pattern of commercial relationships, the flow of economic benefits, and the debtor's continuing conduct in relation to the nominally transferred assets have all been treated as circumstantial evidence capable of establishing sham intent on the civil standard.

There is, however, material variation across circuits. Courts in the Siberian Federal District have in practice applied close scrutiny to nominee-structured real estate transfers in enforcement proceedings, while certain other circuits have historically required a higher evidential threshold before departing from the register of title. Foreign creditors should not assume that judicial treatment of nominee arrangements is uniform across Russia.

Interim measures — including asset freezes — are available in both state court and arbitration proceedings under Russian civil procedure. The creditor's ability to obtain a Russian asset freeze over assets held by a nominee is one of the most practically significant steps in any enforcement strategy: without it, the nominee holder may dissipate or further transfer the asset between the commencement of proceedings and the resolution of the merits.

Russian procedural rules permit asset freezes to be applied to assets held by third parties where the applicant demonstrates a prima facie basis for the claim that those assets are subject to a substantive legal claim and a risk of dissipation. In nominee arrangement disputes, this typically means demonstrating, at the interim stage, that the nominee holder is a connected party, that no genuine consideration was paid for the transfer, or that the circumstances of the transfer are consistent with a sham. Courts do not require proof of the merits at the interim stage — but they do require sufficient factual material to satisfy the plausibility threshold.

Timing is critical. In proceedings before the arbitrazh courts, interim measures may be applied for prior to or contemporaneously with the filing of the principal claim. Applications made after significant time has elapsed — particularly where there is evidence that the respondent has become aware of the investigation — face a higher practical hurdle because courts may draw adverse inferences about the urgency of the relief claimed. In insolvency proceedings, the insolvency administrator has broader standing to seek interim measures against nominee holders, and the evidentiary threshold has in practice been applied less stringently once insolvency proceedings are formally opened.

For creditors who have obtained foreign arbitral awards or foreign court judgments and are seeking recognition and enforcement in Russia, the asset freeze question presents additional complexity. See Asset Tracing & Recovery for the firm's approach to coordinating interim measures with cross-border enforcement. For creditors in parallel insolvency proceedings, see the firm's work in Restructuring & Insolvency.

If you are considering an interim application to freeze Russian assets held through a nominee structure — timing is the primary risk variable. Discuss your matter in confidence: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The following guidance reflects the firm's experience in nominee-arrangement enforcement matters across the arbitrazh courts of the Siberian and Ural federal districts. It addresses the creditor's position at the point where nominee arrangement risks have been identified and an enforcement strategy is being formulated.

The first and most time-sensitive step is investigation and documentation. Before filing any claim, the creditor should assemble all available evidence bearing on the nominee character of the disputed asset. This includes corporate registry extracts for all entities in the apparent holding chain; land and vehicle register extracts showing the current registered titleholder and the history of transfers; published financial statements and tax filings for the nominee holder; any available beneficial ownership disclosure records; and open-source intelligence on the commercial activities of the nominee holder independently of the debtor. In many cases, the most useful initial evidence is negative: a nominee holder that has no employees, no commercial activity, and no independent assets other than those transferred by the debtor is a strong signal of nominee character.

The second step is jurisdiction and forum selection. Most nominee unwinding claims will be heard by the commercial arbitrazh courts. If the debtor is already in formal insolvency, the insolvency case file is typically the most efficient forum: the insolvency administrator has statutory powers of challenge, and the courts' approach to evidence in insolvency avoidance proceedings is generally more expeditious than standalone civil claims. For creditors who have not yet triggered insolvency, the decision to initiate involuntary insolvency proceedings versus pursuing a standalone enforcement claim involves tactical considerations specific to each matter — including the number of creditors, the extent of the nominee chain, and the nature of the assets involved.

The third step is parallel interim relief. Asset freeze applications should be prepared and filed contemporaneously with, or immediately following, the principal claim. Where assets are held across multiple nominee entities, separate applications may be required for each — and the creditor should be prepared to provide security for losses in the event the interim measures prove unwarranted. In complex cross-border matters involving assets in Russia and in other jurisdictions, the firm collaborates with trusted counsel in the relevant foreign jurisdictions to coordinate interim measures. For a description of representative matters in this area, see Matters.

The fourth step is evidentiary strategy for the merits. The creditor should structure the claim to advance alternative legal theories in parallel — sham transaction, insolvency avoidance, unjust enrichment — so that a failure on one ground does not foreclose recovery on another. Each theory requires a distinct evidentiary package, and the pleadings should be drafted to anticipate the nominee holder's most likely defences: bona fide purchaser status, genuine independence from the debtor, and the presence of commercial rationale for the transaction. Addressing these defences in the initial pleadings, supported by the documentary evidence assembled at the investigation stage, materially reduces the risk of the nominee holder obtaining early discontinuance of the claim.

For further analysis of how FAS Russia's enforcement approach intersects with nominee arrangements, see FAS Russia enforcement trends in nominee arrangements. For an examination of how Russian courts have approached the standard of proof in nominee arrangement disputes, see How Russian courts approach nominee arrangements.

For foreign creditors at any stage of a nominee-arrangement enforcement matter in Russia — from initial investigation through to contested proceedings — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• FAS Russia enforcement trends in nominee arrangements
• How Russian courts approach nominee arrangements: evidential standards and outcomes
• Asset Tracing & Recovery: practice overview

Q: Can a foreign creditor directly challenge a nominee arrangement in a Russian arbitrazh court, or is this only available through an insolvency administrator?

A: A foreign creditor with a recognised claim can bring a standalone challenge to a nominee arrangement before the arbitrazh courts without initiating or joining insolvency proceedings. The available grounds include sham transaction, simulated transaction, and unjust enrichment. However, if the debtor is already in insolvency, the insolvency administrator typically has the primary standing to bring avoidance claims, and a creditor wishing to challenge a nominee transfer would generally need to act through the administrator or apply to the court to substitute as claimant if the administrator fails to act. In practice, creditors with significant claims will often apply to the insolvency court to direct the administrator to bring the challenge, or will themselves bring a separate civil claim in parallel.

Q: What evidence do Russian courts require to establish that a transfer was a sham nominee arrangement rather than a genuine arm's-length transaction?

A: Courts have not applied a single fixed evidentiary test, but the pattern of factors considered across arbitrazh court decisions includes: whether the transferor continued to exercise possession and control over the transferred asset after the formal transfer; whether the consideration paid matched the market value of the asset; whether the nominee holder had any independent commercial activity or economic rationale for holding the asset; whether the transfer was accompanied by documentation that did not reflect an arm's-length process (for example, undated transfer-back agreements or powers of attorney); and whether the timing of the transfer correlates with the emergence of creditor claims or an insolvency risk event. No single factor is determinative, and courts have shown willingness to infer sham intent from the cumulative weight of circumstantial evidence.

Q: How long does it typically take to unwind a nominee arrangement through Russian court proceedings?

A: Timeline varies materially depending on the forum, the complexity of the nominee chain, and the willingness of the nominee holder to contest the proceedings. A standalone sham transaction challenge before an arbitrazh court of first instance typically takes between eight and eighteen months to first-instance judgment. An insolvency avoidance challenge, brought within already-opened insolvency proceedings, may be resolved more quickly in routine cases — sometimes within six to nine months of the application — because the procedural framework is more constrained. Both types of proceedings may be appealed through the appellate and cassation levels, which adds further time. In cases involving complex multi-entity nominee chains, the total timeline from initial filing to final resolution frequently extends beyond two years.

Q: Does a Russian asset freeze apply automatically to assets held by a nominee, or must the creditor obtain separate interim relief against each nominee holder?

A: Interim measures under Russian procedural rules operate against specific persons and specific assets — they do not automatically extend to related entities or to assets held by nominee holders who are not named respondents. Where assets are distributed across multiple nominee entities, the creditor will generally need to apply for interim relief against each entity separately, identifying the specific assets in each case. Courts have in some instances granted consolidated freeze orders covering assets held across multiple related nominees when the connectivity between them has been established at the interim stage, but this is not the default position. Creditors should plan for the cost and procedural complexity of multiple parallel applications.

Q: Are nominee arrangement risks materially different for creditors pursuing distressed assets in Russia compared with enforcement in other CIS or EAEU jurisdictions?

A: The conceptual framework — sham and simulated transactions, look-back windows, beneficial ownership rules — exists in varying forms across most CIS and EAEU jurisdictions, reflecting their shared civil law heritage. In practice, however, Russian courts — particularly at the commercial arbitrazh level — have developed a more extensive body of case law on nominee arrangement unwinding than is generally available in other EAEU member states, which means the evidential standards and procedural pathways are better mapped and more predictable. Creditors pursuing distressed assets across multiple CIS jurisdictions should not assume that the Russian approach transfers directly — local counsel is essential in each jurisdiction. Vetrov & Partners is a Russian-qualified firm; for CIS jurisdictions outside Russia, we collaborate with trusted local counsel.

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 and recovery practice advises foreign creditors, distressed investors, and institutional claimants on the identification and enforcement of Russian assets — including assets held through nominee structures, offshore holding chains, and multi-party arrangements. Acting exclusively on the creditor side, the team combines investigative and litigation capabilities with deep knowledge of Russian insolvency and civil enforcement procedure. With over 1,000 matters handled since inception, the firm 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 — Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

When a foreign trade creditor discovers that the Russian entity it pursued for months has transferred its most valuable assets to a connected party weeks before judgment, the practical question becomes urgent: can that transfer be undone? Under Russian civil law and insolvency legislation, the answer is frequently yes — but the grounds for challenge, the procedural route, and the realistic timeline differ materially from what foreign counsel familiar with English, German, or US fraudulent conveyance doctrine will expect. This analysis sets out the framework, identifies the creditor-side pressure points, and explains what a foreign creditor needs to do and when.

Russian law does not use the phrase "fraudulent transfer" as a term of art. The concept is distributed across two bodies of law: the general transaction invalidity provisions of Russian civil legislation, and the specialist transaction-challenge regime within Russian insolvency legislation. For a foreign creditor, understanding which regime applies — and when — is the first analytical step.

Under the general civil law framework, transactions may be challenged on several grounds relevant to asset dissipation. The first ground covers sham transactions — transactions concluded with no genuine intention to create the legal consequences they purport to establish. These are typically used where an asset has been nominally transferred but the debtor retains beneficial control. The second ground covers transactions concluded in bad faith, combining an abuse-of-rights doctrine with the requirement that both parties acted unconscionably. The third covers transactions at a significant undervalue where the weaker party lacked genuine freedom of choice. These are the primary civil law tools available to a creditor who has not yet obtained a judgment in insolvency.

The insolvency-law track is more specific and, in practice, more frequently used by foreign creditors with substantial claims. Under Russian insolvency legislation, a transaction may be challenged as harmful if it was concluded at undervalue, resulted in the preferential satisfaction of one creditor over others, or was carried out in circumstances where both parties knew the debtor was insolvent. The distinction between a preferential transaction and a harmful one determines the look-back period available and the standard of proof required.

The operative distinction for a creditor is between challenges brought outside insolvency and challenges brought within insolvency proceedings. Each has a different court, a different evidentiary standard, and a different enforcement consequence.

Outside insolvency, the general civil law grounds require the creditor to establish both the transaction itself and the subjective element — that the counterparty to the transaction knew or should have known of the debtor's financial distress and the prejudicial intent. Russian courts have held, as a general principle, that transactions between connected or related parties carry a heightened inference of awareness, which in practice shifts some of the evidentiary burden. Courts have not treated this as an absolute presumption, but in proceedings before the Siberian Federal District arbitrazh courts, connected-party transactions at undervalue have routinely attracted close scrutiny.

Within insolvency proceedings, the insolvency administrator — appointed by the court — holds the primary right to challenge suspect transactions, but creditors with a sufficient claim threshold may bring independent challenges with the administrator's consent or, in some circumstances, without it. The look-back window under the prevailing interpretation is typically one year for preferential transactions with connected parties where the debtor was insolvent at the time; the window extends further for transactions that were harmful to the creditor body as a whole, subject to the court's assessment of when insolvency began in fact rather than as declared.

Burden of proof is formally on the applicant, but Russian courts have developed a practical framework in which a creditor who demonstrates the objective elements — undervalue, timing, connection between parties — may place the burden of justification on the respondent. This is not a statutory reversal of burden; it reflects the courts' recognition that documentary evidence of beneficial intent is typically within the respondent's control.

"The most important initial question is always whether the challenge is brought inside or outside insolvency — the answer determines the court, the look-back period, and the prospects of practical recovery." — Elizaveta Razina, Senior Lawyer, Practice Lead — Asset Tracing & Recovery, Vetrov & Partners

The procedural route for a foreign creditor depends on the debtor's status and the stage of the dispute. Three paths are most commonly taken in practice.

The first is a standalone civil claim before the arbitrazh court of the debtor's registered location. This path is available before any insolvency filing and requires the creditor to have an existing judgment or enforceable award against the debtor, or to file the transaction challenge alongside a substantive claim. The advantage is speed relative to insolvency proceedings; the disadvantage is that the creditor bears the full evidentiary burden without the investigative tools available to an insolvency administrator.

The second path is through a creditor's application to initiate insolvency proceedings — thereby obtaining standing within the proceedings to challenge transactions, join the creditors' committee, and exercise supervisory rights over the administrator. Foreign creditors who meet the minimum debt threshold under Russian insolvency legislation may file directly; EAEU and CIS creditors are treated equivalently to Russian creditors in this respect, without additional recognition requirements for the underlying claim.

The third is to intervene as a creditor in already-opened insolvency proceedings, lodge the claim in the insolvency register, and then apply to challenge transactions once registered as a creditor with standing. Timing is critical here. Under the prevailing interpretation of Russian insolvency legislation, late registration does not restore the limitation period for transaction challenges — a creditor who delays registration loses the ability to challenge transactions even if the substantive limitation period has not yet expired at the date of registration. For creditors unfamiliar with Russian insolvency procedure, this is the single most costly procedural error: the window to register, act, and challenge closes progressively, and the insolvency administrator will not pursue a challenge that serves only one creditor's interests.

If your counterparty has entered insolvency or is showing signs of asset transfer — make an enquiry before the registration window closes: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The short answer, for a foreign creditor, is: sometimes — and the analysis is more fact-specific than the domestic case. Where a Russian debtor transfers assets to an offshore vehicle registered in a jurisdiction that recognises Russian court judgments, enforcement of a successful Russian court order against the transferred asset is possible, though it requires separate enforcement proceedings in the receiving jurisdiction.

The practical difficulty is at the Russian end: the challenge must still be brought before a Russian court, and the Russian court must be satisfied that it has jurisdiction over the transaction. Where the asset transferred is real property or a registered right situated in Russia, jurisdiction is not in dispute. Where the asset is a shareholding in a foreign entity, or a receivable governed by foreign law, the Russian court's ability to grant meaningful relief is constrained. Russian courts have, in some circuits, taken a broad view of their jurisdiction over transactions where the Russian debtor was a party, irrespective of the asset's situation; in others, courts have declined to act where the substantive asset sits outside Russia and no Russian enforcement mechanism applies.

For foreign creditors with claims against Russian debtors who have structured assets through Cyprus, UAE, or other jurisdictions commonly used by Russian businesses, a dual-track approach is typically required: a Russian court challenge to the transfer decision, combined with proceedings in the asset's jurisdiction to freeze or recover the underlying asset. The firm's practice in these matters involves coordinating with trusted counsel in the relevant jurisdiction, as Russian-qualified lawyers do not hold admission in foreign jurisdictions.

A further consideration for EAEU-member creditors: the EAEU legal framework includes mutual recognition provisions for court judgments between member states that simplify the enforcement of a successful Russian judgment in Armenia, Belarus, Kazakhstan, and Kyrgyzstan. CIS creditors operate under a different multilateral framework that provides comparable but procedurally distinct recognition routes.

For cross-border asset tracing and recovery, including coordination with counsel in the asset's jurisdiction — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The most consistent finding from the firm's asset tracing and recovery practice is that creditors who act early retain materially more options than those who wait. Russian civil and insolvency law imposes layered limitation periods — for general civil challenges, for insolvency-track challenges, and for the registration of claims in insolvency proceedings — and none of these periods pause while a creditor is assessing the position.

The practical steps for a foreign creditor who suspects asset dissipation are, in order of priority: first, assess whether the counterparty has filed for insolvency or is likely to do so, and if so, register as a creditor immediately; second, obtain and preserve evidence of the transactions in question — Russian arbitrazh courts are receptive to documentary evidence, and notarised copies of publicly available registry records (from EGRYUL, Rosreestr, and the arbitrazh court's own electronic docket) may be obtained without Russian court process; third, obtain a legal opinion on the applicable look-back window and the evidentiary threshold for the specific transaction type; fourth, consider whether interim relief — an asset freeze — is available in the arbitrazh court as a protective measure pending the substantive challenge.

Interim relief in Russian arbitrazh courts requires the applicant to demonstrate a risk of harm if relief is not granted, and to provide security. Courts grant interim freezes in fraudulent transfer proceedings in appropriate circumstances, though the threshold in practice varies by circuit and by the nature of the asset. In the Siberian Federal District, the firm's experience is that courts approach interim applications with appropriate rigour — neither routinely granting nor routinely refusing — and that a well-evidenced application with a credible primary claim materially increases the prospects of an interim order.

Foreign creditors should also consider whether the transaction they seek to challenge was notarially certified — if so, the Russian notarial records may be obtainable and provide contemporaneous evidence of stated consideration that can be tested against market value.

Finally, for those creditors who have not yet obtained a Russian judgment or commenced Russian proceedings: the limitation period for a fraudulent transfer challenge under the general civil framework runs from the date the creditor knew or should have known of the impugned transaction, not from the date of the transaction itself. This doctrine provides some protection against the consequences of delayed discovery, but courts have declined to extend it indefinitely, and a creditor who could have discovered the transfer with reasonable diligence will not be permitted to rely on late actual discovery.

To assess your position and the available grounds for challenge — request our practice review: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Regulatory update: fraudulent transfer analysis under Russian law
• Foreign creditors and fraudulent transfer analysis in Russia: a practitioner's guide
• Asset Tracing & Recovery practice overview

Q: What is the standard look-back period for challenging a fraudulent transfer in Russian insolvency proceedings?

A: The look-back period depends on the type of transaction and the relationship between the parties. For preferential transactions — those that gave one creditor an advantage over others — the prevailing interpretation supports a window of around one year before the insolvency filing date where the counterparty is connected to the debtor; a shorter window typically applies to arm's-length transactions. For transactions harmful to the general creditor body — those at undervalue or with intent to dissipate assets — a longer period is available under the prevailing approach, though its precise extent depends on the court's determination of when actual insolvency began. Foreign creditors should obtain a specific assessment, as the applicable window is determined on the facts of each matter.

Q: Can a foreign creditor challenge a transaction directly, without going through the insolvency administrator?

A: Yes, in certain circumstances. Russian insolvency legislation provides creditors holding a qualifying claim with the right to bring a transaction challenge independently, either with the administrator's consent or, where the administrator has declined to act and the creditor can demonstrate prejudice, without it. Courts have upheld independent creditor challenges where the administrator was passive or where there was a conflict of interest. The procedural prerequisites differ from those applicable to the administrator, and the evidentiary burden falls on the creditor. For foreign creditors, the threshold for independent standing is the same as for domestic creditors once the claim is registered in the insolvency proceedings.

Q: Does Russian law allow courts to look through offshore structures when challenging fraudulent transfers?

A: Russian courts have the power to examine the substance of a transaction regardless of the corporate form used. Where a Russian debtor transferred assets to an offshore entity that it controls or in which it holds a beneficial interest, courts have, in a number of reported decisions, treated the economic substance of the arrangement as determinative rather than its legal form. The extent to which a Russian court will grant effective relief against an asset held in a foreign jurisdiction depends, however, on the nature of the asset and the availability of Russian enforcement mechanisms. Where the underlying asset is in a foreign jurisdiction, practical recovery typically requires enforcement proceedings there — coordinated with Russian proceedings on the transaction challenge.

Q: How does the limitation period work for a creditor who only recently discovered the transfer?

A: Under the general civil law framework, the limitation period for a transaction challenge typically runs from the date the creditor knew or should reasonably have known of the impugned transaction. This means that discovery — not the transaction date — is the starting point, which provides some protection for creditors who learn of a transfer late. Courts have applied this doctrine with some flexibility but are not receptive to arguments that a creditor could not have discovered a publicly registered transaction that was visible on the EGRYUL or Rosreestr record. A creditor is expected to monitor publicly available information concerning its debtor and will generally be held to constructive notice of registered changes. Specialist advice on the applicable limitation position should be obtained before relying on a late-discovery argument.

Q: Is a Russian court judgment invalidating a transfer directly enforceable, or are further steps required?

A: A Russian arbitrazh court order invalidating a transaction and requiring the return of the transferred asset (or its value) operates as an enforceable judgment within Russia. If the asset has been returned to the debtor's estate within insolvency proceedings, the creditor benefits indirectly through the enlarged distributable estate. If the order is directed against an individual or entity holding the asset in Russia, direct enforcement through the Federal Bailiff Service is available. Where the asset or the respondent is located outside Russia, separate enforcement proceedings in the relevant jurisdiction are required. Recognition of Russian arbitrazh court judgments varies by jurisdiction; EAEU member states provide mutual recognition under the EAEU framework; other jurisdictions are assessed on a bilateral treaty or comity basis.

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 international law firms on the identification, tracing, and recovery of assets through Russian civil and insolvency proceedings. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with direct partner involvement on every engagement. Cross-border matters involving asset recovery across multiple jurisdictions are handled in coordination with trusted counsel in the relevant jurisdictions.

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

— Elizaveta Razina Senior Lawyer, Practice Lead — Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

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.

Foreign creditors who reach the door of a Russian court with a judgment or an arbitral award in hand often discover that their counterparty has, in the intervening period, moved, encumbered, or transferred the assets they intended to recover. The practice of interim relief applications in Russian courts exists precisely to prevent that outcome — but the mechanism is tightly regulated, procedurally demanding, and frequently misunderstood by counsel unfamiliar with the Russian legal framework. This analysis examines the substantive grounds, procedural sequence, evidentiary requirements, and practical pitfalls that define interim relief in Russian courts today, with particular attention to the position of foreign creditors pursuing enforcement against Russian debtors.

Under Russian civil procedure, interim relief — referred to in the applicable legislative framework as "provisional measures" or "securing measures" — covers a defined range of court orders issued before or during substantive proceedings to preserve the conditions necessary for enforcement of a future judgment. The concept is analogous to, but materially different from, freezing injunctions under English law or provisional measures under the UNCITRAL framework.

The principal forms of interim relief available in Russian commercial (arbitrazh) courts include: arrest of the respondent's property up to the value of the claim; prohibition on the respondent performing certain actions in relation to specified assets; imposition of obligations on third parties (such as banks or registries) to take or refrain from specific steps; and suspension of enforcement of a challenged administrative act where the claimant contests a tax or regulatory decision. Courts may combine several measures in a single order.

What distinguishes the Russian approach from its common-law counterpart is the absence of a free-standing equitable discretion. Russian courts do not exercise the broad balancing jurisdiction familiar to English practitioners. Instead, the court applies a structured statutory test with defined grounds, a defined category of permissible measures, and a defined procedural pathway. Understanding those three dimensions is the starting point for any foreign creditor considering a trace assets or asset-freezing strategy against a Russian debtor.

The arbitrazh courts — Russia's specialised commercial court network — have developed a substantial body of practice on interim relief applications over the past decade. That practice has tightened significantly. Courts across the Siberian, Ural, and North-West circuits have all, in different procedural contexts, signalled a higher evidentiary threshold than the bare statutory language might suggest. For foreign creditors, this means that an application framed in general terms — asserting that the debtor "may" dissipate assets — is unlikely to succeed.

If you are a foreign creditor considering interim measures against a Russian counterparty, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The statutory test for granting interim relief in Russian commercial proceedings has two limbs. First, the applicant must demonstrate that failure to take the measure would make it difficult or impossible to enforce a future court decision. Second, the applicant must show that the measure is proportionate — that the relief sought corresponds in scope and character to the subject matter of the substantive claim.

Neither limb is self-executing. On the first limb, courts have consistently held that a bare assertion of risk is insufficient. The applicant is expected to point to specific, concrete circumstances suggesting that the debtor is taking steps to reduce or dissipate reachable assets. This may include: evidence of asset transfers to related parties in the period before proceedings; registration of pledges in favour of connected creditors shortly before the claim arose; corporate restructuring that shifts assets out of the entity against which the claim lies; or patterns of conduct from prior dealings that indicate deliberate asset-stripping behaviour.

For foreign creditors unfamiliar with Russian enforcement practice, this evidentiary requirement carries a significant practical consequence. Under Russian insolvency legislation, a debtor's preferential and suspicious transactions may be challenged for periods extending up to three years before a bankruptcy petition — but a creditor who waits to gather comprehensive evidence before filing an interim application may find that the debtor has completed precisely the transfers that the measure was designed to prevent. The window between a creditor's decision to act and the debtor's awareness of that decision is frequently the most consequential interval in a Russian enforcement strategy.

On the second limb — proportionality — courts apply a correspondence test. An application to arrest all assets of a debtor with a claim for a modest contractual sum will be refused or scaled back. The measure sought must be targeted at specific asset classes, correspond in value to the claim as framed, and not impose disproportionate restrictions on the debtor's ordinary commercial activity. This is a live consideration in distressed asset situations where a respondent may be an operating business rather than a dormant holding entity.

An interim relief application may be filed simultaneously with the substantive claim or at any point during proceedings. In urgent cases, it may be filed before the substantive claim, though this pathway carries additional requirements and is reviewed with particular scrutiny.

The court is required to consider an interim application without notifying the respondent — this is the statutory ex parte procedure. The applicable procedural rules require the court to issue its ruling within one day of receiving the application. In practice, that timeline is generally observed in the arbitrazh court system, which distinguishes Russian interim relief from the drawn-out applications familiar in some civil law jurisdictions.

However, speed of issuance does not mean ease of obtaining the order. The burden is on the applicant in the first instance, and a poorly particularised application will be refused summarily. The respondent has a right to apply for the measure to be lifted or modified after it is issued, and that application is considered with the respondent present. If the initial application was thin on evidentiary foundation, the order may be discharged quickly.

Security for loss is a central feature of Russian interim relief practice. Before a measure is granted, the court may require the applicant to provide a counter-security — typically in the form of a cash deposit or bank guarantee — designed to protect the respondent against loss if the underlying claim ultimately fails. The amount is set by the court with reference to the subject matter of the claim. For foreign creditors, this counter-security requirement is a material budget consideration: it may represent a significant proportion of the claimed sum and must be lodged promptly.

After the measure is granted, it is executed through the Federal Bailiff Service in respect of moveable and immoveable property, and through direct notification to banks or asset registries in respect of accounts and registered assets. For foreign creditors tracing Russian assets, the registry notification pathway is often the more reliable channel: banks respond to court orders within defined timeframes, and account arrests are reflected immediately.

If you are advising a client with distressed assets in Russia and need to assess the grounds for an interim application, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The position of a foreign creditor applying for interim relief in a Russian court is procedurally the same as that of a domestic creditor in most respects: the same grounds, the same evidence standard, the same proportionality requirement. However, several cross-border factors materially affect the practical calculus.

First, interim relief in support of foreign arbitration proceedings is available under Russian procedural law. A party to proceedings before an international commercial arbitration tribunal — including institutional arbitrations under LCIA, ICC, or ICAC rules — may apply to a Russian arbitrazh court for provisional measures directed at Russian assets, even before or during the arbitral proceedings. This is a sometimes underutilised route for foreign creditors with Russian counterparties who have commenced or are considering arbitration. The application must specify the arbitration in which it is sought, and the court will examine whether the tribunal has jurisdiction over the underlying dispute.

Second, a foreign creditor holding a final arbitral award that has been recognised by a Russian court may apply for interim measures as part of the enforcement proceedings. At this stage, the standard for the "difficulty of enforcement" limb shifts slightly: a recognised award creates a clearer foundation for asserting enforcement risk, and courts have been more receptive to interim measures in this context than in pre-judgment applications based on contractual claims alone.

Third, foreign creditors face a structural information disadvantage when tracing Russian assets. The range of Russian asset registries is extensive — real property, vehicles, vessels, aircraft, pledges over moveable property, participatory interests in Russian companies — and access to registry data by foreign parties without Russian counsel is limited. An effective interim relief strategy for a foreign creditor pursuing enforcement against a Russian debtor will typically involve preliminary asset-tracing work to identify specific assets before filing the application, so that the arrest order can be targeted at known assets rather than framed in the general terms that courts will refuse.

Fourth, enforcement of foreign court judgments in Russia remains a jurisdiction-specific question. Russia has not ratified a general multilateral treaty on mutual recognition of foreign judgments, and bilateral treaties exist with a limited number of states. For creditors whose underlying entitlement derives from a foreign court judgment rather than an arbitral award, the path to interim relief in Russia is more complex: the recognition proceedings must themselves be commenced, and interim measures may be sought in that context. Counsel familiar with both the asset-tracing practice and the recognition framework is essential at this stage.

For creditors operating across the EAEU or CIS frameworks, enforcement routes and reciprocal recognition arrangements may open additional procedural pathways that are not available under general Russian law — and should be evaluated as part of an integrated recovery strategy.

The most consistent error in interim relief applications filed by foreign creditors in Russian courts is the conflation of legal entitlement with procedural sufficiency. A creditor may have a clear legal right to the underlying claim, a well-drafted contract, and a solid damages analysis — and still obtain a refused application because the evidentiary foundation for the provisional measure was assembled in general terms. Russian courts do not fill gaps in interim applications by inference; they apply the test as presented.

Several practical considerations follow. The application should be drafted around specific evidence of asset-dissipation risk, not abstract assertions. Where available, corporate registry extracts, pledge register searches, and banking or transfer patterns identified through pre-filing asset tracing should be appended as supporting materials. The measures sought should be defined with precision: named bank accounts, identified real property by registry reference, specific shareholdings by entity. The claimed value should match the measure sought, and if the counter-security obligation is anticipated, arrangements for funding it should be made before the application is filed, since the window between the court's demand and the deadline for compliance is short.

Instructing Russian counsel at the earliest point in the dispute — ideally before formal proceedings are commenced abroad or before a demand letter has alerted the debtor — allows for concurrent asset-tracing work, preliminary registry searches, and a considered judgment about the optimal moment to file. In the firm's experience advising foreign creditors in cross-border enforcement matters, the creditors who achieve effective interim relief are those who arrive at the Russian court with a targeted, evidence-based application, not those who file in haste once the counterparty has already received notice of the dispute.

Counsel should also consider the interplay between the interim measure and any parallel insolvency proceedings. If a debtor is likely to file for bankruptcy — or if a creditor is considering filing against the debtor — the interim measure may interact with the insolvency stay in ways that affect its practical utility. The relationship between interim relief and Russian insolvency procedure is a discrete area of practice, explored further in our analysis of Key risk points in interim relief applications and discussed in the context of recent court developments in Court practice shift on interim relief applications.

For foreign creditors with exposure to Russian debtors, an early assessment of the interim relief landscape — before litigation strategy is fixed — is the most reliable way to preserve options. A review of our Asset Tracing & Recovery practice describes the integrated approach the firm takes to cross-border enforcement matters.

To discuss an enforcement matter involving interim relief in Russian courts, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Court practice shift on interim relief applications in Russian commercial courts
• Key risk points in interim relief applications against Russian debtors
• Asset Tracing & Recovery practice overview

Q: What is the main legal test a Russian court applies when deciding whether to grant interim relief?

A: Russian commercial courts apply a two-limb test: the applicant must show that failure to grant the measure would make enforcement of a future judgment difficult or impossible, and that the measure is proportionate to the subject matter of the claim. Neither limb can be satisfied by bare assertion. Courts across the arbitrazh system expect concrete evidence of asset-dissipation risk on the first limb and a clear correspondence between the scope of the measure and the value of the claim on the second. An application that relies on general language about a debtor's potential behaviour will typically be refused.

Q: Can a foreign creditor apply for interim relief in a Russian court before a final judgment or arbitral award has been issued?

A: Yes. Russian procedural law permits interim relief applications to be filed at the commencement of proceedings, during proceedings, or — in urgent cases — in advance of the substantive claim. Where the underlying dispute is being resolved by international commercial arbitration, a foreign creditor may apply to a Russian arbitrazh court for provisional measures directed at Russian assets even before the arbitral tribunal has issued its award. The application must identify the arbitral proceedings, and the court will consider whether the tribunal has jurisdiction over the underlying claim. This route is available under the applicable Russian procedural framework for international commercial arbitration.

Q: What is counter-security, and how does it affect a foreign creditor's interim relief strategy?

A: Counter-security is a deposit or bank guarantee that a Russian court may require the applicant to lodge before or upon granting an interim measure. It is designed to compensate the respondent for any loss suffered if the provisional measure is later lifted and the underlying claim fails. The amount is set by the court by reference to the claim. For foreign creditors, counter-security represents a real liquidity consideration: it must be funded promptly and in the full amount required, or the measure will not be granted or will be discharged. Factoring counter-security into the enforcement budget at the planning stage — rather than treating it as an unexpected obligation — is a standard part of creditor-side strategy in Russian interim relief proceedings.

Q: How does interim relief interact with Russian insolvency proceedings if the debtor files for bankruptcy after a measure is granted?

A: The interaction between an interim measure and a subsequent bankruptcy filing is a nuanced procedural question. As a general rule, the commencement of insolvency proceedings in Russia imposes a stay on individual enforcement actions, which may affect the practical operation of an interim measure already in place. Courts have addressed this interaction in different ways depending on the timing and the type of asset arrested. Creditors who hold an interim measure at the point of a debtor's insolvency filing should seek immediate advice on whether the measure can be maintained, converted into a creditor's claim in the insolvency, or must be lifted. The relationship between interim relief and the insolvency stay is a distinct area of Russian law, and the applicable approach varies by asset class and court circuit.

Q: What practical steps can a foreign creditor take to improve the prospects of a successful interim relief application?

A: The most effective applications are built around specific evidence, targeted measures, and pre-filing asset-tracing work. In practice, this means: conducting preliminary registry searches to identify real property, bank accounts, vehicle and vessel registrations, pledge registrations, and participatory interests before filing; framing the measures sought around those specific identified assets rather than seeking a general arrest of "all property"; ensuring the claimed value corresponds precisely to the scope of the arrest sought; preparing counter-security funding before the application is filed; and instructing Russian counsel early enough to undertake the pre-filing investigation without alerting the debtor. Applications filed in haste, without asset-specific evidence, consistently underperform relative to those prepared with a clear pre-filing trace.

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

The firm's Asset Tracing & Recovery practice advises foreign trade creditors, institutional investors, and distressed asset holders on interim relief strategy, asset-tracing work, and cross-border enforcement against Russian counterparties. The team combines deep procedural knowledge of the Russian arbitrazh court system with direct partner involvement on every engagement. With over 1,000 matters handled since inception, the firm brings a documented track record across the Siberian, Ural, and North-West circuits.

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/

When a foreign trade creditor has obtained a judgment or arbitral award against a Russian debtor and turns its attention to enforcement, the most immediate obstacle is rarely procedural – it is informational. The debtor's assets have often been restructured, transferred, or obscured in the months preceding a formal claim. Third-party disclosure orders, available under Russian procedural law and exercised through the arbitrazh court system, offer creditors a structured mechanism to compel banks, registrars, counterparties, and other third parties to produce information about a debtor's asset position. Understanding how these orders work, when they are available, and what their limits are in practice is among the most operationally important questions a foreign creditor's counsel will face when pursuing recovery against a Russian-registered entity.

Third-party disclosure orders in Russian proceedings are court-issued directives requiring a person or entity that is not a party to the main dispute to produce documents, information, or evidence that is relevant to the proceedings or to the enforcement of a court decision. They sit at the intersection of two distinct procedural functions: evidence gathering during active litigation, and asset tracing in the enforcement phase. Both functions draw on the same underlying power of the arbitrazh court to compel cooperation from third parties, but they operate under different procedural conditions and produce different practical outcomes.

In the evidence-gathering context, a party to arbitrazh proceedings may petition the court to request information or documents from a third party where that party holds relevant material that cannot be obtained through ordinary disclosure between the litigants. The court evaluates the request against criteria of relevance and proportionality. If the petition is granted, the third party – which may be a bank, a state registry, a corporate secretary, a former counterparty, or a regulatory authority – is directed to produce the requested information within a defined period. Non-compliance attracts procedural sanctions, including fines assessed against the non-compliant party.

In the enforcement context, the relevant mechanism operates after judgment. Once a writ of execution has been issued, the bailiff service and, in certain circumstances, the creditor acting through the court, may direct third parties to provide information about the debtor's assets: bank account details, real estate holdings, shareholdings, receivables owed to the debtor, and intellectual property assets. The breadth of the enquiry that can be conducted at this stage distinguishes the enforcement phase from ordinary pre-trial disclosure, because the creditor's standing to compel third-party cooperation is grounded in the enforcement writ itself rather than in the relevance of the information to any disputed question.

For foreign creditors working through the Asset Tracing & Recovery practice, the distinction between these two procedural moments matters considerably. Initiating disclosure requests too early – before a judgment is in hand – carries the risk that the debtor becomes aware of the investigation and accelerates asset transfers. Acting too late – after insolvency has been filed – alters the enforcement landscape entirely, transferring primary control over asset recovery to the insolvency administrator.

The standing to seek third-party disclosure is tied to the procedural status of the applying party and the stage of proceedings. During active arbitrazh litigation, any party to the case may apply to the court to request information from a third party. The application is assessed on the standard of necessity: the applicant must demonstrate that the information sought is relevant to the subject matter of the claim, that the applicant cannot obtain it by other means, and that the request is proportionate in scope. Courts in the Siberian and Ural federal circuits have generally applied these criteria in a manner that gives creditors meaningful access to banking and registry information, though the standard is not perfunctory – overly broad or insufficiently particularised requests are regularly refused.

The range of third parties against whom disclosure can be compelled is broad in principle. It includes:

• credit institutions (banks holding accounts or collateral)
• the Federal Tax Service, which holds registered business address, filing history, and counter-party transaction data
• Rosreestr (the Federal Service for State Registration), holding real estate and mortgage data
• the Central Depositary and registrars of securities, for shareholding information
• the Federal Bailiff Service, for information about existing enforcement proceedings against the debtor
• commercial counterparties of the debtor, where documents held by those counterparties are relevant to proving a claim or establishing asset disposition

State registries occupy a distinct position: courts and the Federal Bailiff Service can compel disclosure from them directly, and in some categories of information – real estate ownership, vehicle registration – creditors acting through a licensed agent or legal representative can submit direct enquiry requests outside the formal litigation channel. This dual-track availability is an important practical feature: it allows a creditor's Russian counsel to build a preliminary picture of disclosed assets before the litigation stage begins, which informs the decision whether to seek pre-trial interim measures simultaneously with the main claim.

For matters involving distressed assets under Russian law, where the debtor is already in financial difficulty, the threshold for third-party disclosure in aid of asset tracing is sometimes lower in practice, because the court is aware of the dissipation risk. This is not a rule – it is a practice observation, and it varies by circuit and by the composition of the panel. However, creditors' counsel should be aware of it when calibrating whether to seek disclosure concurrently with or immediately following the filing of a main claim.

If your counterparty is showing signs of financial distress and you need to establish its Russian asset position before proceedings progress, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The procedural pathway for obtaining a third-party disclosure order in Russian arbitrazh proceedings involves a formal application (petition) filed with the court that is seized of the main matter. The application must specify: the third party by name and address, the information or documents sought with sufficient particularity, the legal basis for the request, the relevance to the proceedings, and the reason why the information cannot be obtained otherwise. Courts will refuse applications that function as fishing expeditions – the specificity requirement is enforced.

Once granted, the order takes the form of a court ruling (opredeleniye), which is served on the third party. The third party has the right to object to the scope of the request or to raise grounds of privilege or statutory confidentiality, most commonly bank secrecy. The resolution of bank secrecy objections is the most frequently contested issue in third-party disclosure practice. Under Russian banking legislation, credit institutions may disclose account information to courts, enforcement bodies, and the tax authority, but the procedural channel through which disclosure is compelled matters. An order directed to a bank in the context of active litigation is processed differently from a bailiff-issued request in the enforcement phase, and creditors' counsel must navigate this distinction carefully to avoid a procedural mismatch that delays the information by weeks or months.

Where a third party fails to comply within the period specified in the court ruling, the sanctions regime operates through the procedural fine mechanism. Fines are assessed by the court on application by the party that sought the disclosure. The amounts available under the arbitrazh procedure rules are not punitive in commercial terms; their primary function is to create a legal obligation and a formal record of non-compliance, which can support further applications, complaints to supervisory authorities, or, in more serious cases, criminal referrals for obstruction.

The most significant practical limitation of third-party disclosure orders in Russian proceedings is that they do not stop assets from moving while the disclosure is being processed. A creditor who obtains an order directing a bank to disclose the debtor's account balances will learn what those balances were at the time of disclosure – not necessarily what they are by the time enforcement steps are taken. This is why, for creditors pursuing recovery of distressed assets under Russian law, the standard practice is to couple a disclosure application with a simultaneous application for interim asset-freezing measures (obespechitelnyye mery). The two instruments are procedurally distinct but strategically interdependent: disclosure tells you where the assets are; the freeze prevents them from leaving.

"The practical value of third-party disclosure in Russian proceedings depends almost entirely on whether interim protective measures are sought concurrently – without a freeze, disclosure can become a map of assets the debtor has already moved." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

For foreign creditors enforcing Russian assets, two layers of complexity arise that are absent in a purely domestic creditor situation. The first is the recognition and enforcement gateway: a foreign creditor who has obtained an award or judgment outside Russia must first clear the recognition stage before having full standing to deploy Russian enforcement tools, including third-party disclosure in the enforcement phase. During active recognition proceedings, the creditor's procedural status is that of an applicant in a separate case, not yet an execution creditor. This constrains, though does not eliminate, the ability to seek third-party disclosure concurrently with the recognition application.

The second layer concerns the interaction between Russian enforcement proceedings and parallel proceedings in other jurisdictions. Where a foreign creditor is pursuing parallel enforcement tracks – for example, against Russian assets in Russia and against assets held in Cyprus or the Netherlands through separate proceedings – the question arises whether information obtained via a Russian third-party disclosure order can be used in the foreign proceedings, and vice versa. Under Russian law, court orders issued in Russian proceedings are not subject to automatic mutual recognition in most foreign jurisdictions, and the reverse is equally true. A foreign disclosure order or equivalent instrument (such as a Norwich Pharmacal order under English law) does not compel a Russian bank or registrar to produce information in response to a foreign court's direction unless a separate Russian court order is obtained. This asymmetry is a consistent feature of cross-border asset recovery work involving Russian law, and it means that foreign creditors should treat Russian third-party disclosure as a distinct procedural track rather than as an extension of their home-jurisdiction discovery process.

Creditors who delay initiating enforcement proceedings in Russia risk losing the ability to prioritise their recovery position: under Russian insolvency legislation, preferential transfer claims may be brought for transactions completed within prescribed periods before the bankruptcy filing, and assets distributed in that window may be challenged – but only if the creditor is an active participant in the insolvency at the relevant time.

The practical implication is that foreign creditors with Russian debtors should instruct local Russian counsel at the earliest viable point – ideally before or simultaneously with proceedings in the home jurisdiction – to preserve the option of deploying Russian third-party disclosure tools while the debtor's asset position is still traceable. Waiting until a foreign judgment is final and then seeking recognition in Russia can extend the timeline to enforcement by a year or more, during which the debtor's asset position may have changed materially. See further discussion in Third-party disclosure orders in Russian proceedings and A practical guide to third-party disclosure orders.

For creditors with exposure in multiple CIS or EAEU member states, it is worth noting that information-sharing frameworks between courts and enforcement bodies within that grouping create some additional channels for asset tracing that are not available in purely bilateral relationships between Russia and non-member states. These frameworks do not replace the domestic Russian disclosure procedure, but they may supplement it where the debtor holds assets across multiple EAEU jurisdictions.

For in-house counsel managing a Russian enforcement file where the debtor has assets in multiple jurisdictions, an early assessment of the Russian disclosure options is an important step before the enforcement strategy is fixed. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Effective use of third-party disclosure orders in Russian proceedings requires treating disclosure not as a standalone application but as one component of a sequenced enforcement strategy. Based on the firm's experience acting for foreign creditors in asset tracing and recovery matters, the following framework reflects the approach that yields the most consistent results.

The first step is a pre-filing asset survey. Before any disclosure application is made, a preliminary picture of the debtor's publicly available asset footprint should be constructed using open registry sources: Rosreestr data for real estate, the Unified State Register of Legal Entities (EGRUL) for corporate information and registered charges, court database searches for existing proceedings against the debtor, and the Federal Bailiff Service register for active enforcement writs. This information is obtainable by a Russian counsel without a court order and without alerting the debtor. It shapes the subsequent disclosure application by identifying which registries and third parties hold the most relevant information and whether assets are already the subject of competing claims.

The second step is to assess the timing of any interim measures application. If the preliminary survey reveals a significant disclosed asset base that is at risk of dissipation – for example, a large cash balance at a named bank or a real estate asset without existing encumbrances – the creditor's counsel should consider filing an application for a Russian asset freeze concurrently with the main claim (or, in some procedural configurations, as a pre-claim protective measure). The threshold for a pre-claim Russian asset freeze is higher than for an in-claim freeze, and courts apply it cautiously, but it remains available and has been granted in creditor-side mandates where the dissipation risk was demonstrated with specific evidence.

The third step is to calibrate the scope of the disclosure application to the information already gathered. A well-constructed application targets the gaps in the picture – the bank accounts not yet identified, the shareholdings not reflected in public registries, the receivables owed to the debtor by known counterparties. Disclosure requests that are particularised in this way are materially more likely to be granted than omnibus requests for "all financial information" relating to the debtor, which courts routinely narrow or reject.

The fourth step is to monitor enforcement actions and anticipate insolvency. In distressed situations, the period between a creditor's active enforcement and a debtor's voluntary or creditor-initiated insolvency filing is often measured in months, not years. A creditor who has already obtained third-party disclosure and an asset freeze is in a structurally stronger position when insolvency is filed: it has a clearer picture of the estate, it is already on the register of creditors, and it has evidence of asset transfers that may support challenge proceedings. A creditor who has been waiting for the outcome of foreign recognition proceedings before engaging Russian counsel may arrive at the insolvency with none of these advantages.

For the Restructuring & Insolvency dimension that frequently accompanies distressed asset recovery, the interaction between disclosure tools and the insolvency administrator's own powers is a point that creditors' counsel should address explicitly in the strategy, as the administrator's access to debtor information is considerably broader than that available to individual creditors outside insolvency.

For a structured review of the disclosure and enforcement options available against a Russian debtor, our team is available for an initial 30-minute meeting – complimentary. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Third-party disclosure orders in Russian proceedings
• A practical guide to third-party disclosure orders in Russia
• Asset Tracing & Recovery practice

Q: Can a foreign creditor obtain a third-party disclosure order in Russian proceedings before it has a Russian judgment or arbitral award?

A: A foreign creditor that is a party to active arbitrazh proceedings in Russia – either as a claimant pursuing a primary claim or as an applicant in recognition proceedings – may petition the court to direct third parties to produce information relevant to those proceedings. The creditor does not need a final Russian judgment in hand before the disclosure application is made; it needs only to be a party to proceedings that are already before the court. However, the scope of available disclosure is more limited at this stage than in the enforcement phase: it is restricted to information that is relevant to the subject matter of the pending proceedings, rather than extending to the full asset tracing function that becomes available once an execution writ is issued. The strategic implication is that starting Russian proceedings early – rather than waiting for a foreign judgment to be recognised – preserves access to this earlier, broader window of disclosure opportunity.

Q: Which third parties are most commonly compelled to produce information in Russian asset tracing proceedings, and what information can be obtained from them?

A: In practice, the most operationally significant third parties in Russian asset tracing proceedings are credit institutions (banks), Rosreestr, and the Federal Tax Service. Banks are the primary source of account balance and transaction history information; Rosreestr holds real estate ownership and mortgage data; the Federal Tax Service holds registered counterparty and financial filing information. Securities registrars and the National Settlement Depository are the relevant sources for shareholding information. The Federal Bailiff Service register provides real-time visibility into existing enforcement writs against the debtor, which is essential for assessing the creditor's priority position. State registries can also be queried through administrative channels by a licensed Russian representative without a court order for certain categories of public information, providing a baseline asset picture before formal proceedings begin.

Q: How does the Russian asset freeze interact with third-party disclosure orders, and should both be sought at the same time?

A: The Russian asset freeze (interim protective measure) and the third-party disclosure order are procedurally distinct instruments that serve complementary functions. The freeze prevents identified assets from being dissipated pending resolution of the main claim or enforcement proceedings; the disclosure order identifies assets that may not yet be known to the creditor. In a well-constructed enforcement strategy, both are typically sought, but not necessarily simultaneously. Where the pre-filing survey has already identified assets at dissipation risk, the freeze application should be filed concurrently with the main claim. The disclosure application then follows to fill gaps in the picture. Where the asset position is wholly unknown, counsel may file the disclosure application first and seek a freeze once the results identify attachable assets. Courts in most circuits will consider an asset freeze application that is filed promptly once disclosure results are received, though the creditor's position is strongest when the freeze application can be supported by specific asset evidence.

Q: What happens to third-party disclosure orders obtained in Russian proceedings if the debtor subsequently files for insolvency?

A: The opening of insolvency proceedings materially alters the enforcement landscape for a creditor who holds a disclosure order or an interim asset freeze. Active enforcement actions by individual creditors are stayed on the opening of insolvency, and the management of the debtor's estate passes to the insolvency administrator. Disclosure orders that have already produced results remain in the creditor's possession and may be used as evidence in the insolvency – for example, to support a claim that specific assets were transferred in the suspect period and are subject to avoidance. Disclosure orders that have not yet produced results, and interim freezes, are subject to review by the insolvency court. The creditor's procedural focus should shift at this point from individual enforcement to active participation in the insolvency as a creditor – registering the claim, attending creditors' meetings, and engaging with the insolvency administrator's own disclosure process, which provides access to the debtor's books and records on a basis that is considerably broader than what individual creditors can compel outside insolvency.

Q: Can information obtained via a Russian third-party disclosure order be used in parallel enforcement proceedings in another jurisdiction?

A: Information obtained via a Russian third-party disclosure order is produced pursuant to a Russian court order and subject to the confidentiality and admissibility rules of Russian procedural law. Its use in foreign proceedings is governed by the rules of the foreign jurisdiction and the specific evidentiary standards of that forum. In most common law jurisdictions, documentary evidence obtained lawfully in a foreign jurisdiction is in principle admissible, subject to authentication and relevance requirements. In practice, bank statements, registry extracts, and other documents produced in Russian disclosure proceedings have been used successfully in foreign enforcement and freezing order applications. However, creditors' counsel in the foreign jurisdiction should review admissibility at an early stage and, where necessary, obtain the documents in a form that meets the authentication standards of the target court – which may require notarisation, apostille, or sworn translation depending on the jurisdiction.

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 and recovery practice advises foreign creditors, institutional investors, and distressed-asset acquirers on enforcement against Russian-registered debtors and Russian-held assets. The practice combines deep procedural knowledge of Russian arbitrazh and insolvency proceedings with direct partner involvement on every engagement. With over 1,000 matters handled since inception, the team is experienced in the full range of enforcement tools available to foreign creditors under Russian procedural law, including third-party disclosure orders, interim asset freezes, and cross-border recovery coordination.

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/

For a foreign creditor seeking to establish or enforce a claim with a Russian nexus, obtaining documentary evidence held by Russian authorities presents a procedural challenge that few foreign litigation systems prepare practitioners for. International letters rogatory — formal judicial requests transmitted through diplomatic or designated channels — are the standard mechanism under Russian civil procedure for securing evidence from abroad. Yet the failure rate among letters rogatory directed at Russian authorities is disproportionately high, driven not by political resistance but by compliance deficiencies that are entirely avoidable. This checklist sets out the six requirements that counsel must satisfy before a request reaches a Russian court or ministry.

Russian civil procedure recognises letters rogatory transmitted through two primary channels: multilateral conventions to which Russia is a party, and bilateral mutual legal assistance treaties. The applicable framework determines the competent authority, the required format, and the permissible scope of the request.

Russia is a party to the 1970 Hague Convention on the Taking of Evidence Abroad in Civil or Commercial Matters. However, Russia's accession came with a declaration excluding the right to take evidence by diplomatic or consular officers and by private commissioners — meaning pre-trial depositions conducted on Russian soil by foreign counsel are not available under this route. What remains is the formal request channel: the request is transmitted to the Russian Ministry of Justice as the designated Central Authority.

For creditors whose proceedings arise in jurisdictions party to the 1993 CIS Convention on Legal Assistance or the 2002 Chisinau Convention (superseding it for most CIS members), a parallel and in some respects more direct route exists. These instruments are familiar to Russian courts from intra-CIS enforcement, and the procedural forms are standardised.

Where no multilateral convention applies, bilateral treaties govern — Russia maintains such arrangements with a significant number of European and Asian states. Counsel should confirm treaty status early: proceeding under the wrong instrument will result in the request being declined at the receiving end without substantive engagement.

Note: Where no treaty basis exists between the requesting state and Russia, letters rogatory may still be transmitted through diplomatic channels on a comity basis. Russian courts are not obliged to execute such requests, and in practice do so infrequently. Creditors relying on a comity-only basis should factor in the material risk of non-execution when planning their evidence strategy.

If you are assessing the treaty basis for a letters rogatory request directed at Russian authorities, make an enquiry at this stage: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Even when the treaty basis is confirmed, misdirection of the request is a frequent cause of delay and return without execution. Russian civil procedure assigns responsibility for receiving and forwarding incoming letters rogatory to the Ministry of Justice of the Russian Federation for civil and commercial matters, with regional courts and arbitrazh courts executing the request at the local level.

For criminal matters, the route passes through the Prosecutor General's Office — a distinction that matters in asset tracing contexts where the foreign proceedings have a mixed civil and criminal character (for example, where the creditor is also a victim in fraud-related proceedings). Sending a civil-track request to the criminal-track authority, or vice versa, will not result in cross-routing; it will result in return.

Within Russia, the Ministry of Justice transmits the executed request to the competent court in the district where the evidence or the compelled witness is located. Counsel should therefore identify, at the drafting stage, which regional court is likely to be assigned execution — and ensure that the request's geographical scope matches the location of the target evidence. A request directed at documents held in Novosibirsk will be assigned to a Siberian circuit court, not to a Moscow court.

Note: Requests directed at the Federal Tax Service, the Central Bank of Russia, or Rosreestr (the state property register) do not follow the standard Ministry of Justice route. These regulatory bodies have their own procedures for responding to foreign judicial requests, and in some cases require the request to be accompanied by a separate letter from the Russian diplomatic mission of the requesting state. Verify the correct route for each institutional target before dispatch.

Russian procedural rules require that incoming letters rogatory be accompanied by a certified translation into Russian. This is not a discretionary requirement — an untranslated or partially translated request will not be executed.

The translation must be of the entire request document, including any appended schedules, exhibit lists, and the court order or judicial authorisation that forms the basis of the request in the requesting jurisdiction. Partial translations — common where counsel translates the operative paragraphs but not the procedural recitals — are a recurring compliance failure.

Authentication requirements vary by treaty channel. Under the Hague Evidence Convention, legalisation (apostille) is not required for the request document itself — the Convention operates without that formality. Under bilateral treaty channels, the position differs: most bilateral mutual legal assistance agreements require the request to bear the seal of the requesting court and, in some cases, to be authenticated through the diplomatic post of the requesting state.

If the request is transmitted through diplomatic channels without a treaty basis (comity), apostille or full legalisation of the request document is typically expected by Russian authorities. Counsel should confirm the applicable authentication standard by reference to the specific instrument before certifying the package as complete.

Note: Translation quality is assessed by the receiving Russian court. Translations that are technically accurate but use non-standard legal terminology inconsistent with Russian procedural vocabulary may result in execution being suspended pending clarification. Commission the translation from a specialist in Russian procedural documents, not from a general legal translation service.

Russian law provides several grounds on which execution of a foreign letters rogatory request may be refused. Understanding these grounds in advance allows counsel to draft around them where possible, or to exclude evidence types that will predictably fail.

The principal grounds for refusal are: execution would conflict with the sovereignty or security of the Russian Federation; the request is not within the competence of the requested court or authority; and execution would be contrary to Russian public policy. These are broad formulations, and their application is not always predictable. However, certain categories of request reliably encounter difficulty.

Requests directed at obtaining banking records from Russian credit institutions are sensitive. While Russian financial institutions are legally compelled to cooperate with court-ordered evidence requests in domestic proceedings, the position for foreign judicial requests is more complicated — particularly where the underlying proceedings are in a jurisdiction whose legal framework Russia does not recognise as equivalent for these purposes.

Requests that effectively constitute pre-trial discovery — gathering broad categories of documents to identify what evidence may exist, rather than to obtain specific identified evidence — are not consistent with Russian procedural culture and will frequently be refused or returned with a request for specification. Russian civil procedure is document-specific rather than disclosure-based; the letters rogatory must identify the evidence sought with precision.

Requests that overlap with an ongoing Russian criminal investigation or pending insolvency proceedings raise additional complications. The principle of priority of domestic proceedings will be invoked where the Russian authorities determine that execution of the foreign request would prejudice a live domestic process. Creditors operating in a context where their Russian counterparty is also a subject of domestic investigation should take specialist advice before issuing the letters rogatory request.

Creditors facing refusal risk on a letters rogatory request, or operating in a context involving parallel Russian proceedings, should take advice before dispatch: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The substantive drafting of the request is where foreign counsel most frequently underestimate the Russian procedural standard. Russian courts executing letters rogatory apply a specificity requirement that reflects domestic civil procedure norms: the request must identify the evidence sought by reference to specific documents, specific persons, or specific transactions, not by reference to categories.

A request framed as "all correspondence between [counterparty] and [target institution] relating to the transfer of assets" will be treated as insufficiently specific. A request framed as "the account opening documentation, signature card, and transaction records for account [number] held at [institution] in the name of [entity], for the period [dates]" is responsive to the standard.

The request must also specify the legal basis of the requesting proceedings, the relevance of the evidence to those proceedings, and — where compulsion of a witness is sought — the questions to be put. Russian procedure does not permit open-ended witness examination; the questions must be formulated in advance and submitted as part of the request.

Where the creditor does not yet hold sufficient identifying information to satisfy the specificity standard — a common situation in asset tracing where the purpose of the request is to establish the whereabouts of assets — the letters rogatory route may not be the most effective first step. Counsel should consider whether preliminary relief from the requesting court (to compel disclosure from parties within that court's jurisdiction) can generate the identifying information needed to draft a compliant Russian request.

Russian law recognises certain privilege and confidentiality protections that may be invoked by the holder of the evidence to resist execution of a letters rogatory request. The most relevant in creditor-side asset tracing matters are banking secrecy, attorney-client privilege (advokatskoye sokhranenie), and the protections attaching to information classified as commercial secret.

Banking secrecy under Russian law is broad: credit institutions are prohibited from disclosing account information and transaction records except to specified categories of domestic authority. A foreign letters rogatory request, even properly transmitted through the Ministry of Justice, does not automatically override banking secrecy — the executing Russian court must make a specific order compelling disclosure, which the financial institution may challenge. The strength of this challenge will depend on the treaty basis and the degree to which the requesting court's order is framed as compulsory.

Commercial secret protections may be invoked by corporate entities holding documents — including the Russian counterparty itself if it is the compelled party. These protections are not absolute, but they introduce delay and the possibility of partial execution: the entity may produce redacted versions pending the resolution of a challenge before the executing court.

Counsel should anticipate these challenges at the drafting stage by including in the request an explicit statement that the evidence is sought for use in identified legal proceedings, that the requesting court has jurisdiction over those proceedings, and that the requesting state's law provides equivalent protections for similar evidence if compelled in that jurisdiction. This framing does not guarantee success, but it strengthens the executing court's basis for ordering full disclosure over a privilege objection.

The execution of international letters rogatory through Russian civil procedure is not a rapid process. Under standard timelines — without complications arising from privilege challenges, misdirection, or translation deficiencies — the period from transmission to receipt of executed evidence is typically measured in months rather than weeks. Where complications arise, the period extends further and is not subject to a hard deadline enforceable by the requesting party.

Under the Hague Evidence Convention framework, Russia has not specified a fixed execution period. The Convention asks for prompt execution but does not impose sanctions for delay. Bilateral instruments vary: some specify that the requested state should execute within a defined period (commonly three to six months), but these provisions are aspirational rather than strictly enforced in practice.

For creditors whose evidence strategy is time-sensitive — for example, where a limitation period in the requesting jurisdiction is running, or where asset dissipation is an active risk — letters rogatory alone is an insufficient protective measure. In these circumstances, counsel should pursue parallel strategies: applications for interim relief before the requesting court, preservation orders where the assets are within a jurisdiction that will enforce them, and — where the Russian-nexus assets include registered intellectual property or real estate — registration searches through public Russian registries that do not require a letters rogatory process.

In a recent matter, the firm acted for a foreign trade creditor seeking to establish the ownership structure of Russian assets pledged as security. The letters rogatory process was initiated in parallel with registry searches and a preservation application in the creditor's home jurisdiction — a sequenced approach that allowed the creditor to act on registry evidence within six weeks while the letters rogatory process ran its course over several months.

Note: If limitation in the requesting jurisdiction will expire before the letters rogatory process completes, issue the substantive claim before the evidence is received. Russian civil procedure does not extend limitation periods in foreign jurisdictions; the creditor bears the risk of a time-barred claim if the evidence strategy is allowed to delay the commencement of proceedings.

For creditors planning a time-sensitive evidence strategy that includes Russian elements, an initial conversation about sequencing can save significant costs: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: When are international letters rogatory the appropriate mechanism for obtaining evidence from Russia?

A: Letters rogatory are the appropriate mechanism when the evidence sought is held by a Russian authority, financial institution, or compelled third party that will not produce it voluntarily, and when the requesting court's jurisdiction extends to ordering its production but not to enforcing that order in Russia directly. They are particularly relevant in creditor-side asset tracing where the creditor needs to establish the Russian asset base of a debtor who is not cooperating. Where evidence is held by a private party who is a defendant or respondent in the requesting proceedings, alternatives such as disclosure orders against that party (within the requesting court's jurisdiction) or witness summons should be considered first — letters rogatory are most effective when voluntary production has been exhausted or is plainly unavailable.

Q: Are there circumstances where Russian authorities may decline to execute a foreign letters rogatory request?

A: Yes. Russian civil procedure provides grounds for refusal that include conflict with Russian sovereignty or public policy, lack of competence of the requested court, and situations where execution would prejudice a live domestic proceeding. In practice, the most common causes of non-execution are not these substantive grounds but rather formal compliance failures: missing translation, insufficient specificity, incorrect routing, or absence of a treaty basis. A well-drafted and correctly transmitted request directed at obtainable evidence rarely encounters substantive refusal; the compliance burden is the greater practical risk.

Q: What happens if a letters rogatory request is returned unexecuted or only partially executed?

A: The requesting party has limited direct recourse within the Russian procedural system. The appropriate response depends on the reason for non-execution: if the request was returned for a formal deficiency, it can be corrected and resubmitted — though this adds months to the timeline. If it was refused on substantive grounds, the requesting party may seek a review through diplomatic channels, but this is slow and rarely produces a different outcome at the level of the Russian executing court. In cases of partial execution, the requesting party should assess whether the evidence obtained is sufficient to proceed, or whether the gap can be addressed through other means — public registries, third-party disclosure in the requesting jurisdiction, or interim applications. The firm's Asset Tracing & Recovery practice advises on sequenced evidence strategies that account for the risk of partial or failed execution from the outset.

• Rospatent guidance on international letters rogatory: implications for IP asset tracing
• International letters rogatory directed at Russian authorities: procedural overview
• Asset Tracing & Recovery in Russia

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years and 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 their counsel on locating and recovering assets with a Russian nexus — including through international judicial assistance mechanisms, registry-based investigation, and parallel enforcement proceedings. With over 1,000 matters handled since inception, the team works directly with partners on every engagement, without delegation to junior fee-earners.

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

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

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.

Foreign creditors pursuing recovery of distressed assets in Russia face a procedural constraint that frequently goes unaddressed until it is too late: Russian currency control law imposes affirmative repatriation obligations on residents and, in certain configurations, creates regulatory exposure for the foreign counterparty as well. Under Russian currency control legislation, the failure to repatriate funds or to document the basis for retaining them abroad can trigger administrative liability — and, at higher thresholds, criminal exposure — entirely independently of whether the underlying commercial claim is well-founded. This checklist is structured for creditors, their advisers, and in-house counsel at foreign companies with Russian assets who need to map the regulatory landscape before enforcement steps are taken or contested.

Russian currency control law distinguishes between two obligations: the obligation to receive payment under a foreign-trade contract into a Russian resident's account, and the separate obligation to repatriate funds that have been transferred or held abroad in breach of the applicable rules. Both obligations apply to Russian residents — legal entities and individuals registered or operating in Russia — rather than to foreign creditors directly. However, a foreign creditor seeking to enforce a judgment or arbitral award against a Russian counterparty must understand which of these obligations the counterparty is already subject to, because that analysis directly affects where assets are held and what the Russian debtor's own regulatory incentives are.

The currency control regime is administered by the Federal Tax Service and the Bank of Russia acting in coordination. Their respective mandates create overlapping supervisory authority: the Bank of Russia sets the regulatory framework for cross-border currency transactions, while the Federal Tax Service enforces compliance through audits and administrative proceedings. For a foreign creditor, the practical significance is that assets a Russian debtor should have repatriated may in fact still be abroad — and that the debtor has both regulatory exposure and, paradoxically, a domestic enforcement problem of its own.

Note: Russian currency control regulations have been subject to significant amendment since early 2022, with multiple rounds of government decrees modifying the standard framework. The rules described in this checklist reflect the structural obligations under the standing legislation; the current application of any specific mandatory repatriation deadline or permitted exemption must be verified against the most recently published decree-level modifications before any enforcement action is initiated.

Not every cross-border transaction between a Russian resident and a foreign counterparty triggers the repatriation obligation in the same way. The scope of currency control applies differentially depending on: the type of contract (goods, services, loans, intellectual property licensing, investment), the residency classification of the parties, and whether the transaction was routed through accounts at Russian authorised banks or through foreign accounts.

For a foreign creditor, the key scope questions are:

• Is the Russian counterparty a resident for currency control purposes? Russian residents include legal entities incorporated under Russian law, Russian citizens, and certain foreign nationals with Russian permanent residence. Subsidiaries of foreign companies incorporated in Russia are residents.
• Was the relevant contract registered with an authorised Russian bank? Contracts above the applicable monetary threshold must be registered, and the registration record determines which repatriation deadlines apply.
• Does the contract fall within a category for which exemptions or deferrals have been issued by government decree? Several categories — including certain commodity contracts and intercompany transactions within EAEU member-state groups — carry modified obligations.
• Are the assets the creditor is targeting held in a Russian account, a foreign account, or a mixed structure? The answer affects both tracing methodology and enforcement sequencing.

This scope mapping should be completed before any enforcement application is filed. The results determine which regulatory authority's records may be accessed in disclosure proceedings and whether the debtor's own currency control compliance file at its authorised bank constitutes a usable evidence source.

If your recovery strategy involves cross-border assets and you need to map scope before filing — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The repatriation obligation under Russian currency control law attaches to specific deadlines set either in the contract itself (for certain transaction types) or by the applicable regulatory instrument. In the standard framework, a Russian resident must receive the foreign currency or rouble equivalent of a payment due under a foreign-trade contract by the date specified in that contract. If payment is not received and the resident fails to take demonstrable steps to enforce recovery, the resident is exposed to administrative liability calculated as a percentage of the transaction amount per day of delay — a figure that in practice accumulates rapidly on larger contracts.

For the foreign creditor, this mechanism creates a recoverable leverage point. A Russian debtor that has failed to meet its own repatriation obligations is already under regulatory pressure from the Federal Tax Service and, depending on the amounts involved, from the Bank of Russia. In enforcement proceedings, counsel can use the debtor's regulatory compliance file — or the gap in that file — as evidence of the debtor's financial position and conduct.

Note: At transaction amounts above the criminal threshold under Russian law, the failure to repatriate can give rise to criminal liability for the directors of the resident entity — a consequence that the Federal Tax Service can refer to the Investigative Committee. This exposure does not transfer to the foreign creditor, but it is material to the debtor's negotiating position and to any assessment of the debtor's willingness to reach a consensual resolution.

Checklist items to verify on deadlines:

• What deadline applies to the specific contract type? Confirm whether a decree-level deferral or exemption is in effect.
• Has the Russian counterparty registered the contract with an authorised bank? If so, the bank's transaction passport contains the applicable deadline on record.
• Is the limitation period for the administrative offence still open? Administrative currency control offences carry their own limitation period, which is separate from the contractual limitation period.
• Has any partial repatriation occurred? Partial compliance affects the penalty calculation.

Under Russian insolvency legislation, preferential transfer claims may be brought for transactions completed up to three years before a bankruptcy filing — a window that foreign creditors unfamiliar with Russian law frequently underestimate when evaluating whether a debtor's pre-insolvency asset movements can be challenged.

Creditors who delay initiating enforcement proceedings risk losing priority in an insolvency filing the debtor controls the timing of. For a confidential assessment of your position — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Once the repatriation landscape is mapped, the foreign creditor has several enforcement routes available in Russia, with sequencing decisions that significantly affect recovery outcomes. The primary routes are:

• Claim before the Russian arbitrazh court: for commercial disputes between legal entities. Arbitrazh courts have jurisdiction over cross-border commercial claims where the Russian counterparty is domiciled in Russia. Interim relief — including account freezing orders and injunctions over Russian assets — is available on application at the claim-filing stage.
• Recognition and enforcement of a foreign arbitral award: under the New York Convention, to which Russia is a party, foreign arbitral awards from Convention states are in principle enforceable before Russian arbitrazh courts. The recognition procedure involves filing an application with the arbitrazh court at the debtor's domicile. Grounds for refusal exist but are narrowly applied in practice by courts that have developed a body of recognition jurisprudence. See Russian Supreme Court clarification on asset recovery for recent guidance on the applicable standard.
• Creditor participation in Russian insolvency proceedings: if the Russian debtor is already subject to insolvency proceedings, the foreign creditor must submit a claim to the register of creditors within the statutory period. Late submission results in subordination to registered creditors in the distribution hierarchy — a materially worse recovery position.
• Asset tracing applications in parallel: where assets have been transferred out of the Russian entity, counsel can apply to the arbitrazh court for the imposition of subsidiary liability on controlling persons (directors, shareholders) — a mechanism that Russian courts have applied with increasing frequency in creditor-initiated insolvency proceedings.

The Asset Tracing & Recovery practice page sets out the firm's approach to enforcement sequencing in detail. Creditors with active claims should also review Navigating asset repatriation and Russian currency rules for the procedural overlay.

A record in the Matters hub illustrates the firm's approach to cross-border creditor recovery in practice.

Currency control obligations under Russian law apply uniformly to Russian residents regardless of the nationality of the foreign counterparty. However, EAEU member-state integration creates a distinct layer: certain cross-border transactions between Russian residents and counterparties in Armenia, Belarus, Kazakhstan, and Kyrgyzstan are subject to modified obligations — including broader exemptions from mandatory repatriation under specific treaty instruments.

For CIS states that are not full EAEU members, the position is more varied. Several bilateral investment and trade treaties between Russia and CIS member states contain provisions that interact with the domestic currency control framework, and the applicable rule requires treaty-by-treaty analysis.

The practical implications for a foreign creditor:

• A creditor from an EAEU member state may be able to structure enforcement through a treaty-compliant mechanism that reduces regulatory friction at the Russian end.
• A creditor from a CIS state outside the EAEU should obtain specific advice on whether the relevant bilateral treaty displaces the default repatriation obligation for its class of transaction.
• A creditor from outside the EAEU and CIS should proceed on the basis of the standard Russian currency control framework, subject to any applicable decree-level modifications in force at the time of enforcement.

The EAEU and CIS carve-outs do not affect the enforcement routes available to the foreign creditor in Russian courts; they affect only the regulatory compliance position of the Russian resident counterparty.

For creditors with cross-border structures involving EAEU or CIS jurisdictions — an initial scoping discussion is available without charge: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The Russian administrative code provides for penalties against Russian residents who fail to repatriate funds in accordance with the applicable rules. The penalty structure is graduated: for each day of delay, a percentage of the outstanding amount is assessed as an administrative fine. At higher thresholds — involving large transaction amounts and extended non-compliance periods — the matter can be referred for criminal investigation under provisions addressing evasion of currency repatriation obligations.

For the foreign creditor, the direct exposure is limited: the administrative and criminal liability falls on the Russian resident, not on the foreign counterparty. However, three indirect consequences are material to a creditor's recovery analysis:

• The regulatory file is an evidence source. If the Federal Tax Service has opened an administrative file against the Russian debtor for repatriation non-compliance, that file is potentially accessible in civil and insolvency proceedings and may contain transaction records, account details, and bank correspondence that are otherwise unavailable to the creditor.
• Director exposure creates negotiating leverage. Where the repatriation failure is attributable to decisions taken by the debtor's management, those individuals face personal administrative — and potentially criminal — liability. This changes the calculus for a consensual resolution.
• Penalty accrual reduces available assets. Accumulating administrative fines reduce the assets available for distribution to creditors. Creditors who delay filing can find that the assets against which they are seeking recovery have been partially absorbed by regulatory penalties.

Note: The precise daily penalty rate and the criminal threshold applicable at any given time are subject to legislative adjustment. Verify the current figures against the standing administrative code provisions and any applicable decree before quantifying the debtor's regulatory exposure in settlement discussions.

Enforcement proceedings before Russian arbitrazh courts impose documentary requirements that differ from those familiar to foreign practitioners. A creditor's file should be assembled before the application is filed, not incrementally during proceedings.

The documentation package for a standard enforcement application includes:

• Authenticated copies of the underlying contract — with an apostille (or notarisation, where apostille is not available) and a certified Russian translation where the contract is in a foreign language.
• Evidence of the debt — invoices, delivery notes, acceptance certificates, bank transfer records, correspondence acknowledging the debt. Russian courts require contemporaneous documentation, not retrospective reconstruction.
• Confirmation of the counterparty's Russian registration — an extract from the Unified State Register of Legal Entities (EGRUL) dated within 30 days of the application.
• Power of attorney for Russian counsel — a duly apostilled or notarised power of attorney authorising the Russian representative to act in proceedings. This document must comply with Russian procedural rules as to form; defects in this document are a common cause of rejected filings.
• State duty payment confirmation — Russian arbitrazh courts require proof of payment of the state duty (gosposhlina) at the applicable rate before accepting the claim.
• Translation certification — all foreign-language documents must be accompanied by a certified translation into Russian executed by a certified Russian translator.

Note: If the contract or award includes a foreign currency amount, the conversion into roubles for the purposes of the state duty calculation must be made at the Bank of Russia's official exchange rate on the date of filing. An error in this calculation delays acceptance.

For creditors holding a foreign arbitral award rather than a primary contract claim, the recognition package has additional requirements specific to the New York Convention procedure before Russian courts.

• Russian Supreme Court clarification on asset recovery
• Navigating asset repatriation and Russian currency rules
• Asset Tracing & Recovery — practice overview

Q: Does Russian currency control law impose any obligations directly on the foreign creditor?

A: As a general rule, Russian currency control obligations fall on Russian residents — the Russian legal entity or individual who is party to the cross-border contract. A foreign creditor is not itself subject to Russian currency control requirements by virtue of holding a claim against a Russian debtor. However, the foreign creditor's conduct can become relevant if it is alleged that the creditor participated in a scheme to evade repatriation — a risk that is remote in standard trade creditor situations but cannot be entirely discounted in complex intragroup or structured-finance arrangements. For practical purposes, the foreign creditor's analysis of currency control law is about understanding the debtor's regulatory position, not managing its own regulatory exposure.

Q: What happens to a foreign creditor's claim if the Russian debtor is already in insolvency proceedings?

A: Once Russian insolvency proceedings are opened, the foreign creditor must submit its claim to the register of creditors within the statutory period from the date of publication of the insolvency notice. Failure to submit within that period results in the claim being placed in a subordinated queue, behind registered creditors in the order of priority distribution. Russian insolvency proceedings have distinct priority tiers — costs of the proceedings, employee claims, tax authority claims, and then general unsecured creditors — and a late-registered foreign creditor will typically recover only from whatever remains after all higher-priority claims are satisfied. The currency control compliance position of the debtor is separately relevant to whether assets were unlawfully transferred before the insolvency filing and can be recovered through challenge proceedings.

Q: Can a foreign creditor access the Russian debtor's currency control compliance records in enforcement proceedings?

A: Access to a debtor's currency control records — including transaction passport data held at the authorised bank — is not available as of right to a foreign creditor in civil enforcement proceedings. However, several disclosure mechanisms exist. In insolvency proceedings, the insolvency manager has broad investigative powers and is required to identify and disclose asset movements. In civil proceedings, the arbitrazh court can, on application by the creditor, request information from the Federal Tax Service and the Bank of Russia where that information is relevant to the assessment of the claim. In practice, the most productive route to currency control records is via the insolvency manager in bankruptcy proceedings or via court-ordered disclosure in contested enforcement applications.

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 trade counterparties on recovery of claims against Russian entities — including tracing asset movements, initiating and participating in insolvency proceedings, and enforcing foreign arbitral awards and judgments before Russian arbitrazh courts. With over 1,000 matters handled since inception, the team combines detailed procedural knowledge of the Russian enforcement landscape with 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/

When a foreign creditor holds an English court order against a Russian counterparty, the instinct is to treat the judgment as the end of the process. In Russia, it is the beginning of a separate set of proceedings. English court orders have no direct effect in Russian territory: they cannot be served on a bailiff, registered against an asset, or used to freeze a bank account without first passing through Russian recognition procedure. For foreign creditors holding distressed assets or pursuing enforcement against a Russian debtor, the structure of that procedure — and its current practical limitations — determines whether recovery is achievable at all.

This checklist sets out the six steps a foreign creditor should complete before, during, and after filing for recognition of an English court order in Russia. Each item identifies the legal requirement, the practical difficulty, and the recommended action. The checklist is designed for creditors who have already obtained judgment and are now assessing whether Russian enforcement is viable.

Russian courts recognise foreign judgments on one of two grounds: a binding international treaty between the Russian Federation and the judgment state, or a demonstration of reciprocity — meaning that Russian judgments receive equivalent treatment in the foreign jurisdiction. There is no bilateral treaty on the mutual enforcement of civil and commercial court judgments between the Russian Federation and England. This absence is the central practical obstacle for any creditor enforcing English court orders in Russia.

In the absence of a treaty, Russian arbitrazh courts (which handle commercial matters) and courts of general jurisdiction (for non-commercial claims) apply the reciprocity doctrine. The doctrine is discretionary: courts assess whether English courts have historically recognised Russian judgments on comparable terms. Russian courts have, as a general matter, been sceptical of reciprocity arguments where the foreign state has no formal enforcement instrument with Russia. Creditors should obtain a reasoned legal opinion on the current state of reciprocity analysis before committing to proceedings.

Note: Failing to identify the correct legal basis at the outset will typically result in the recognition application being returned without consideration. Russian courts apply procedural grounds for return strictly, and a rejected application does not reset the enforcement timeline.

Recognition proceedings without a corresponding asset search are procedurally correct but practically purposeless. Before filing, a foreign creditor should establish what assets the Russian debtor holds, where they are registered, and whether any prior encumbrances exist. Under Russian civil procedure, enforcement is asset-specific: a recognition order does not create a general charge over the debtor's estate.

Creditors who delay asset identification risk a narrowing recovery window. Russian procedural law permits a debtor to continue disposing of assets between the date an English order is made and the date a Russian court grants interim relief. The gap between those two events — in contested recognition proceedings — can extend to several months. Asset disposals completed before a Russian interim measure is granted are, as a general rule, beyond the immediate reach of that measure, though fraudulent transfer claims may be available as a separate remedy in appropriate circumstances.

Effective asset searches in Russia require engagement with the relevant registries — immovable property, corporate participations, and vehicle registrations — as well as commercial database analysis. The firm's Asset Tracing & Recovery practice routinely conducts pre-filing asset mapping for foreign creditors.

If you hold an English judgment against a Russian debtor and have not yet mapped the available Russian assets, early engagement with local counsel is advisable. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Russia is a member of both the Commonwealth of Independent States (CIS) and the Eurasian Economic Union (EAEU). The CIS Minsk Convention of 1993 and the Kyiv Agreement of 1992 establish mutual enforcement frameworks among CIS member states for civil and commercial judgments. England is not a member of the CIS or the EAEU, and neither instrument applies to English court orders.

The 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards — to which both Russia and the United Kingdom are parties — governs arbitral awards, not court judgments. A creditor who holds an English court order, rather than an arbitral award, cannot rely on the New York Convention. If the underlying contract contained an arbitration clause, and the creditor obtained an arbitral award rather than (or in addition to) a court judgment, the enforcement route in Russia is materially more favourable and should be pursued in parallel or instead.

For English court orders specifically, the applicable framework remains Russian domestic private international law. Creditors should verify at the outset which instrument they hold — court order, arbitral award, or both — and confirm the correct Russian procedural route for each. See the related analysis on legislative amendments affecting the enforcement of English court orders for current procedural developments.

Russian jurisdiction over recognition claims follows the location of the debtor or the debtor's assets. For commercial entities, recognition applications are filed with the arbitrazh court of the relevant subject of the Russian Federation — not with federal courts of general jurisdiction, which handle non-commercial matters. Filing in the wrong court category results in a transfer of the case, which adds delay and may require re-filing of translated documents.

The application must be accompanied by certified translations into Russian of all principal documents: the judgment itself, any orders ancillary to it, proof of service on the debtor in the original proceedings, and the applicant's authority documents. Russian courts apply the translation and legalisation requirements strictly. Defects in the document package are among the most common grounds for procedural return of recognition applications.

The limitation period for bringing a recognition claim in Russia runs from the date the foreign judgment becomes enforceable. As a general rule, creditors should treat this period as running concurrently with any domestic appeal window in England — meaning that delay in instructing Russian counsel after the English judgment is handed down directly reduces the available enforcement window in Russia. See the practitioner briefing on enforcing English court orders in Russia for document-preparation requirements.

Once a recognition application is filed, a creditor may apply to the Russian court for obespechitelnyye mery — interim protective measures — to prevent the debtor from dissipating assets pending the outcome of the recognition proceedings. These measures can include an asset freeze over identified bank accounts, prohibitions on the registration of transactions affecting real property, and restrictions on share transfers in Russian corporate entities.

Russian courts may grant interim measures on an ex parte basis in urgent circumstances, though in practice courts often require a hearing. The evidential threshold is that the applicant demonstrate a real risk of asset dissipation. Documentary evidence — evidence of asset movement, transfer attempts, or insolvency signals — materially strengthens the application. A bare assertion of risk is unlikely to suffice.

The firm has assisted foreign creditors in obtaining interim protective measures in Russian arbitrazh courts in connection with distressed asset recovery matters. Relevant experience across cross-border enforcement is described on the Matters page.

For foreign creditors at the interim measures stage, timing is the determining factor. If you need to assess whether an asset freeze application is viable in your matter, contact us to discuss: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Russian courts may refuse recognition of a foreign judgment on a defined set of grounds rooted in Russian private international law. The most commonly invoked in practice are: (a) the foreign judgment has not entered into legal force in the jurisdiction where it was made; (b) the defendant was not properly served and had no meaningful opportunity to participate in the foreign proceedings; (c) a Russian court is already considering the same dispute between the same parties; (d) recognition would violate Russian public policy (ordre public). Each of these grounds requires active rebuttal by the applicant's Russian counsel rather than passive reliance on the English court's findings.

The public policy ground is the most unpredictable. Russian courts have applied it to refuse recognition where the English judgment contained remedies with no direct Russian equivalent, or where the underlying transaction was characterised as contrary to Russian mandatory norms. Creditors should have their Russian counsel assess the public policy risk specific to their judgment before filing — not after a refusal is received.

Where a Russian court refuses recognition, the order may be appealed within the Russian appellate hierarchy. The evidentiary record built at first instance is critical: Russian appellate courts do not generally admit fresh evidence that was available but not adduced below.

Note: A refusal of recognition on public policy grounds does not extinguish the underlying debt under Russian law. Creditors whose recognition applications have been refused should consider alternative recovery mechanisms — including participation in any Russian insolvency proceedings affecting the debtor, or pursuing separate claims under Russian substantive law — in parallel with Restructuring & Insolvency counsel.

If a Russian court has refused recognition of your English order or you are anticipating a public policy challenge, we can advise on the available options. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Legislative amendments affecting the enforcement of English court orders in Russia
• Enforcing English court orders in Russia: a practitioner briefing
• Asset tracing for foreign creditors in Russia: an overview

Q: Can an English court order ever be enforced in Russia without a bilateral treaty?

A: In principle, yes — Russian courts have discretion to recognise foreign judgments on the basis of reciprocity, without a formal treaty. In practice, however, Russian courts have generally required creditors to produce substantial evidence that English courts recognise Russian judgments on equivalent terms before accepting reciprocity. The outcome is circuit-dependent and subject to judicial discretion. Creditors should not assume that a reciprocity argument will succeed without a prior assessment by Russian counsel of the current state of practice in the relevant jurisdiction and court.

Q: Are there situations where Russian courts have recognised English judgments outside a treaty framework?

A: Recognition of English court orders under the reciprocity doctrine has occurred, but it is the exception rather than the prevailing pattern. Some Russian commercial courts have entertained comity-based arguments, particularly where the debtor had a substantial Russian presence and the creditor had produced evidence of a consistent English enforcement practice towards Russian judgments. The strength of the application — the quality of the evidence, the completeness of the document package, and the specific public policy profile of the judgment — is determinative in marginal cases.

Q: What happens if a Russian debtor transfers assets after an English order is made?

A: Transfers completed before a Russian court grants interim protective measures are, as a general matter, enforceable against a creditor seeking asset freeze relief in the recognition proceedings. A creditor's primary protection is speed: filing the recognition application and the interim measure application promptly reduces the window during which unprotected transfers can occur. Where transfers have already taken place, a separate fraudulent transfer challenge may be available under Russian civil law, provided the creditor can demonstrate that the debtor acted with intent to hinder recovery and that the transferee was not a bona fide purchaser for value. Early specialist advice is advisable; the Asset Tracing & Recovery practice can assess viability.

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 on the enforcement of foreign court orders and arbitral awards in Russia, interim protective measures in Russian courts, asset identification, and recovery strategy in distressed situations. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of Russian enforcement law with 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 – Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

Foreign creditors instructed to recover assets from a Russian counterparty frequently encounter the same obstacle: financial evidence that is technically available but procedurally unusable. Under Russian law, the standards governing the admission and weight of forensic accounting evidence in civil and enforcement proceedings are exacting — and the gap between what a foreign forensic specialist can produce and what a Russian arbitrazh court will treat as probative is wider than most creditors anticipate. This checklist is designed for in-house counsel, distressed-asset investors, and foreign advisers who are at the early stages of an asset investigation involving Russian entities or Russian-linked offshore structures.

The first question any forensic engagement must answer is whether the foreign creditor has procedural standing to compel or commission the disclosure that forensic analysis requires. Under Russian civil procedure, a creditor's right to seek information disclosure — through a court-ordered request, a bankruptcy trustee's powers, or a subsidiary creditor committee right — depends on the nature of its claim and its formal status in any ongoing proceedings.

A trade creditor holding a contractual debt may have different access rights from a pledge-holder or a bondholder. Where insolvency proceedings have been opened, the bankruptcy trustee (арбитражный управляющий) is the primary party authorised to conduct forensic analysis and to request financial documentation from third parties. Foreign creditors who have not registered their claims in the insolvency register in time may find their ability to compel disclosure significantly limited.

Before commissioning forensic work:

• Confirm whether Russian insolvency proceedings have been opened or are imminent
• Establish the formal status of your claim (contractual, pledged, judgment debt, or other)
• Verify registration of the claim in the insolvency creditor register if proceedings are open
• Identify whether a trustee is already conducting financial analysis — duplication is inefficient and potentially counterproductive
• Clarify the legal basis for requesting financial records from Russian counterparties and related entities

Note: Under Russian insolvency legislation, claims not registered within the prescribed period after the commencement notice is published lose ordinary priority. The window is short and strictly enforced by the courts. Foreign creditors who miss it face substantial recovery risk even where the underlying debt is uncontested.

If you are uncertain about your standing as a foreign creditor in Russian proceedings, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Forensic accounting in Russian asset investigations is resource-intensive. Engaging specialists before the asset map is adequately developed often produces analysis that is either misdirected or too narrow to support enforcement. The firm's experience in Asset Tracing & Recovery matters suggests that creditors consistently underestimate the complexity of ownership structures involving Russian operating companies, Cypriot or BVI holding vehicles, and Russian real estate or equipment holdings registered in the names of affiliated entities.

The asset mapping stage should address:

• Russian legal entities controlled by or associated with the debtor — including indirect shareholding chains
• Offshore holding structures with Russian-source assets (particularly where Cyprus, the Netherlands, or UAE vehicles are used)
• Real property registered with Rosreestr (the Federal Registration Service) — both residential and commercial
• Bank accounts and financial instruments held at Russian credit institutions
• Receivables owed to the debtor by Russian counterparties

The output of this stage should be a documented ownership diagram — even a preliminary one — that forensic specialists can use to prioritise their financial analysis. Without it, forensic work proceeds without strategic direction and the resulting reports are rarely structured in a way that Russian courts find useful.

For complex structures involving insolvency alongside asset tracing, the firm's Restructuring & Insolvency practice works alongside the asset recovery team where the two mandates overlap.

This is the item that most commonly disrupts foreign creditor investigations. Evidence gathered by a foreign forensic accounting firm — even an internationally respected one — is not automatically admissible in Russian civil or commercial proceedings. Russian courts apply their own rules on documentary evidence, and a report produced under, say, English forensic accounting standards will need to satisfy Russian procedural requirements before it is given any weight.

The following practical points apply:

• Expert reports from foreign specialists must typically be accompanied by a translation into Russian certified in a manner recognised by Russian courts
• A report produced outside Russia may require legalisation (apostille) and, in some cases, notarial authentication of the translation
• The methodology underlying the forensic analysis should be capable of explanation in terms that correspond to standards recognised in Russian forensic examination practice
• Where the foreign forensic report will be used to support a transaction-avoidance claim (e.g. attacking preferential or undervalue transactions in insolvency), the analysis should follow the chronology and evidentiary logic that Russian insolvency courts apply to such claims
• Alternatively — and often more effectively — consider commissioning a parallel Russian-qualified financial expert at the outset, whose report can be used directly in proceedings

For a detailed analysis of how Russian courts approach the weight and admissibility of forensic accounting evidence, see How Russian courts approach forensic accounting evidence.

Limitation periods under Russian civil and insolvency legislation are among the most consequential procedural constraints for foreign creditors. They are strictly applied, and Russian courts rarely exercise discretion to extend them absent highly specific statutory grounds.

The general limitation period under Russian civil law is three years from the date the creditor knew or ought to have known of the violation. For transaction-avoidance claims within insolvency proceedings, the periods are calculated differently and may run from the date the bankruptcy trustee discovered or should have discovered the relevant transaction — not necessarily from the date of the transaction itself.

Foreign creditors frequently lose recovery opportunities not because the underlying claim is weak, but because limitation issues were not identified at the outset of the forensic engagement.

• Identify the date from which limitation runs for each claim type you intend to pursue
• Assess whether any act or omission by the debtor has interrupted or suspended the limitation clock
• Where insolvency proceedings are open, determine whether the trustee has brought or intends to bring avoidance claims — and whether the creditor can independently pursue such claims if the trustee does not
• Document the moment at which your client first had knowledge of the relevant facts — this is a litigation-critical date

Note: Under Russian insolvency legislation, transaction-avoidance claims (including claims targeting asset disposals at undervalue and preferential payments to connected parties) carry their own specific limitation periods that differ from the general civil limitation rule. Missing these periods extinguishes the claim — no equitable extension applies. Forensic analysis should be directed, from the outset, to the transactions that fall within the remaining limitation window.

Forensic accounting analysis conducted outside the framework of Russian court proceedings has limited standalone utility. The ultimate purpose of the analysis — whether to support an enforcement application, an avoidance claim, a criminal complaint, or a creditor challenge to a trustee decision — determines how the findings must be structured and who must formally present them.

In Russian arbitrazh court proceedings, financial expert evidence is most effective when it is commissioned by or through the court process itself (a судебная экспертиза — a court-appointed expert examination). Where the court appoints the expert, the findings carry significantly greater weight than a party-commissioned report.

This does not mean that pre-litigation forensic work is wasted — far from it. It means that the foreign creditor's forensic findings are typically the foundation for an application to the court to commission its own expert examination. The quality and specificity of the pre-litigation analysis largely determines whether that application is granted.

For recent judicial guidance on how Russian courts are framing forensic accounting requests in asset-tracing contexts, see Supreme Court enforcement trends in forensic accounting matters.

• Confirm the procedural vehicle through which forensic findings will be introduced (party-commissioned report, court-appointed expert, trustee analysis, or criminal complaint support)
• Identify who has standing to make the application for a court-appointed expert examination
• Ensure that any pre-litigation forensic report addresses the specific questions the court is likely to direct to a court-appointed expert — this maximises the chance that the court's expert mandate covers the issues you need resolved
• Where a criminal complaint is part of the strategy, understand that Russian criminal procedure uses different evidentiary standards — forensic analysis built for civil proceedings may need adaptation

Note: Engaging Russian-qualified counsel to co-ordinate the forensic team before the litigation phase begins is not optional — it is the mechanism by which the pre-litigation analysis becomes useful in court. Foreign creditors who commission forensic work through a foreign adviser and then instruct Russian counsel at the point of filing typically find that significant rework is required. The matters the firm has handled in the Asset Tracing & Recovery practice consistently reflect this pattern. For an overview of instructed matters, see the firm's Matters.

For foreign creditors at the pre-litigation stage of a Russian asset investigation, a structured review of the forensic strategy is the most efficient first step — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• How Russian courts approach forensic accounting evidence in asset-tracing proceedings
• Supreme Court enforcement trends: forensic accounting in Russian insolvency matters
• Asset Tracing & Recovery practice — Vetrov & Partners

Q: Does a foreign creditor need a Russian court order before engaging forensic specialists on Russian assets?

A: No court order is required to commission preliminary forensic accounting analysis. However, the legal basis for obtaining financial documents and records from Russian entities — rather than from materials already in the creditor's possession — typically requires either a court order, access through insolvency proceedings, or co-operation from the bankruptcy trustee. Forensic analysis conducted solely on the basis of publicly available information (corporate registry filings, real estate records, published financial statements) does not require any procedural authorisation. Analysis that requires compelled disclosure from the debtor or third parties does.

Q: Will a forensic report produced by a foreign accounting firm be accepted by a Russian arbitrazh court?

A: Not automatically. A report produced by a foreign forensic specialist is treated as party-commissioned evidence, which carries a lower evidentiary weight than a court-appointed expert examination. For it to be used effectively, it must be translated into Russian, the methodology must correspond to principles recognised in Russian forensic examination practice, and it must be structured to address the specific legal questions relevant to the proceedings. In practice, the most effective approach is to use the foreign forensic report as the analytical foundation for an application to the court to appoint its own expert, whose mandate is shaped by the pre-litigation findings.

Q: What is the consequence of missing a limitation period in a Russian insolvency-related asset recovery claim?

A: The claim is extinguished. Russian courts apply limitation periods strictly and have very narrow statutory grounds on which to extend or restore them. The most common category of loss for foreign creditors in Russian asset investigation matters is not the absence of a meritorious claim — it is the failure to identify and act within the applicable limitation period before instructing forensic specialists. Limitation assessment should be the first substantive legal step in any Russian asset investigation, not an afterthought.

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 distressed-asset buyers on the identification, tracing, and enforcement of claims against Russian-linked assets. With over 1,000 matters handled since inception, the team combines deep procedural knowledge across the Siberian and Ural federal districts with direct partner involvement on every engagement.

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

Make an enquiry — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

When a foreign creditor holds a claim against a Russian counterparty, and evidence suggests that assets are distributed across Russian and European jurisdictions, the recovery process is rarely a question of choosing the right forum. It is a question of coordinating two or more parallel proceedings so that each reinforces rather than undermines the other. Foreign creditors — and the European counsel who instruct Russian lawyers on their behalf — consistently encounter the same set of missteps: assets dissipated before proceedings are secured, priority lost to later-filing creditors in Russian insolvency, and interim relief granted in one jurisdiction rendered ineffective because corresponding steps were not taken in the other. This checklist sets out the principal coordination requirements under Russian law requirements for cross-border asset recovery, addressed to creditors who are active or about to become active in a dual-jurisdiction enforcement.

The first discipline of cross-border asset recovery Russia work is comprehensive asset mapping before any procedural step is taken. Once proceedings are commenced in either jurisdiction, the debtor is alerted and the window for pre-action preservation narrows sharply.

In Russia, the principal asset registers that a creditor's counsel should examine include: the State Register of Legal Entities (EGRUL) for corporate shareholdings and entity status; the Unified State Register of Immovable Property (EGRN) for real estate and registered pledges; and the State Register of Pledges for movable property. Bank account information is not publicly available in Russia and requires a court order or tax authority request; counsel should plan for this delay when timing procedural steps.

In European jurisdictions, the equivalent registers vary by country, but the combination of company registries, land registries, and — where available — beneficial ownership registers typically provides sufficient preliminary intelligence to identify the asset footprint.

The output of this stage should be a dual-jurisdiction asset map: a working document that identifies each asset class, its registered holder, the jurisdiction of registration, and any encumbrances already on record. This document becomes the foundation for every subsequent coordination decision. Creditors who skip this stage and proceed directly to filing frequently find themselves applying for interim relief over assets that are already pledged, transferred, or dissolved.

If you are tracing assets across Russia and European jurisdictions and need a preliminary assessment of the recoverable asset base, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Not all Russian assets are equal from a cross-border asset recovery Russia analysis perspective. The jurisdiction in which an asset is located or registered determines which Russian court will have territorial competence, which enforcement authority will execute a judgment, and which insolvency proceedings will govern a pledged asset if the debtor files.

For real estate, the competent Russian arbitrazh court is generally the court at the asset's location. For corporate claims — including claims arising from shareholdings in a Russian company — the competent court is typically the court at the company's registered address. For movable property subject to a pledge, enforcement is conducted through the bailiff service (FSSP), but the supervisory arbitrazh court's circuit will affect how contested enforcement is handled on appeal.

A creditor instructing Russian counsel should confirm the following at the outset: in which Russian federal circuit is each principal asset located? Does any asset fall within the Siberian Federal District, the Ural circuit, or other circuits where local procedural practice differs materially from Moscow? Are any assets held through intermediate holding companies with registered addresses in a different circuit from the underlying asset?

Understanding the jurisdictional footprint at this stage prevents wasted procedural steps and allows counsel to consolidate related proceedings wherever Russian procedure permits.

Timing is the most consequential coordination variable in dual-jurisdiction cross-border asset recovery. The sequence in which proceedings are filed — and in which interim relief is obtained — determines whether the creditor can establish and hold priority against competing creditors and against the debtor's own restructuring efforts.

Under Russian civil procedure, a claimant may apply for interim measures (обеспечительные меры) at the time of or before filing its substantive claim. The application is considered without notice to the respondent, and a decision is typically issued within one working day. However, the interim measure only takes effect once the court order is registered with the relevant enforcement authority or asset register. For real estate, this requires registration with the EGRN; for shares in a Russian company, notification of the registrar. These registration steps take additional time and must be built into the coordination plan.

In European proceedings, the equivalent interim steps vary but broadly follow a similar logic: the creditor must act before the debtor can dissipate or transfer the assets. Where a European freezing order or Mareva-type injunction is obtained first, Russian counsel must assess whether that order has any recognition effect in Russia — in most cases it does not, and a parallel Russian application is required regardless.

Note: Under Russian insolvency legislation, transactions effected within one year before a bankruptcy petition is filed may be challenged as ordinary preferences, and transactions within three years may be challenged as transactions made to the detriment of creditors. A creditor who delays commencing Russian proceedings while pursuing European enforcement may find that, by the time it files in Russia, the debtor has already submitted a voluntary bankruptcy petition, converting the creditor's enforcement claim into a creditor's claim in insolvency proceedings — with materially different priority consequences. The window for acting as an enforcement creditor rather than an insolvency creditor is typically the most time-sensitive decision point in the entire recovery.

The effective distressed assets Russian law framework for interim relief requires a creditor to demonstrate: a substantiated claim (prima facie evidence of the debt or obligation); a causal link between the relief sought and the preservation of the claim; and proportionality between the measure and the amount sought. Russian arbitrazh courts apply these criteria with varying degrees of scrutiny across circuits; in practice, well-documented claims with supporting contracts, payment records, and correspondence tend to succeed on interim applications at a higher rate than claims relying on secondary or inferential evidence.

The categories of interim relief available in Russian proceedings include: arrest of bank accounts; prohibition on disposing of identified movable or immovable property; suspension of corporate decisions (relevant where the debtor is a Russian company whose shareholders may resolve to transfer assets or reorganise); and injunctions prohibiting registration of encumbrances. The choice of measure must be matched precisely to the asset class identified in the dual-jurisdiction asset map prepared at Item 1.

For creditors simultaneously seeking interim relief in a European jurisdiction, the key coordination requirement is documentary consistency: the supporting evidence filed in the European court and the evidence filed in the Russian arbitrazh court should reflect the same factual narrative. Inconsistencies between filings — which courts in both jurisdictions may notice if the debtor or its counsel draws attention to them — can undermine both applications. European counsel and Russian counsel must align on the factual and legal characterisation of the claim before any application is filed.

For foreign creditor Russia enforcement matters where dual-jurisdiction interim applications need to be filed concurrently, the firm can act as Russian counsel and coordinate directly with your European instructing firm. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Russian civil procedure does not incorporate a general disclosure or discovery obligation equivalent to those in common-law systems. A party in Russian arbitrazh proceedings is expected to file the evidence it relies upon with its claim; the court may request specific documents from the opposing party, but broad disclosure orders are not a feature of Russian practice.

This asymmetry creates a coordination challenge for creditors who are pursuing common-law proceedings — in England, Germany, the Netherlands, or other European jurisdictions with more developed documentary disclosure regimes — alongside Russian proceedings. Documents obtained through European disclosure may be submitted in Russian proceedings as written evidence, subject to the standard requirements for foreign-language documents: certified translation into Russian and, depending on the document's origin, legalisation or apostille. Counsel should plan for translation and authentication lead times of two to four weeks for standard commercial documents.

The reverse direction — using Russian court proceedings to obtain evidence for use in European proceedings — is possible through letters rogatory and the relevant bilateral treaty frameworks, but is slow and procedurally demanding. In practice, creditors who need evidence from Russian sources for European proceedings are better served by exhausting available public register searches and obtaining a Russian court order for bank account information than by relying on mutual legal assistance procedures.

A practical discipline for this item: before filing in either jurisdiction, counsel should identify each category of documentary evidence it expects to rely upon; confirm the location and holder of each category; and build an authentication and translation schedule into the overall case timeline.

The final checklist item is also, in practice, the one that generates the most significant and irreversible losses for creditors who delay. In Russia, a creditor's position in insolvency proceedings depends almost entirely on when and how it filed its creditor claim in the bankruptcy case.

Under Russian insolvency legislation, creditors are divided into priority classes. Secured creditors — those holding a registered pledge over Russian assets — have a stronger position than unsecured creditors, but even secured creditors must file their claims within the statutory period to be included in the creditor register. Claims filed late may be included in the register but lose voting rights and rank after timely-filed claims of the same class in distributions.

For a foreign creditor tracing assets in Russia, the key monitoring obligation is this: if there is any indication that the Russian debtor may file for bankruptcy — including deteriorating financial disclosures, defaults to other creditors, or restructuring rumours in the market — a protective creditor claim should be prepared in advance and filed as soon as a Russian insolvency case is opened. The filing of a claim does not prevent a creditor from continuing to pursue assets outside insolvency; but failing to file means the creditor may miss the statutory deadline entirely.

Note: Under Russian insolvency legislation, the standard period for creditors to file their claims in the creditor register after the opening of an insolvency case is two months from the date the relevant notice is published in the Fedresurs (Federal Resource on Bankruptcy). This deadline is strict; courts have limited discretion to reinstate a creditor who misses it. For foreign creditors who rely on European-language press or their own monitoring rather than the Russian-language Fedresurs publication, the deadline is frequently missed. Creditors should instruct Russian counsel to monitor the Fedresurs for debtor filings as a standing instruction, not as a reactive step.

Creditors who are uncertain whether a Russian debtor has filed or is preparing to file for insolvency should request an immediate Fedresurs check. Discuss your matter with the team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What is the single most important sequencing decision in cross-border asset recovery involving Russian assets?

A: The most consequential decision is whether to pursue enforcement proceedings in Russia before or concurrently with European proceedings, rather than waiting for a European judgment and attempting to enforce it in Russia afterward. Russian courts do not automatically recognise foreign court judgments, and the enforcement of foreign arbitral awards requires a separate recognition procedure before a Russian arbitrazh court. A creditor who obtains a European judgment and then attempts to enforce it in Russia will face a recognition process that takes several months and has specific procedural requirements — during which time the debtor may have dissipated Russian assets or filed for insolvency. The standard approach in cross-border asset recovery Russia matters is to file Russian proceedings — or at minimum interim applications — concurrently with, not after, European proceedings.

Q: Does a foreign court freezing order automatically prevent a Russian debtor from dealing with its Russian assets?

A: No. Foreign court orders — including freezing orders issued by English, Dutch, or German courts — do not have automatic effect in Russia. A Russian arbitrazh court will not act on a foreign court order unless it has been formally recognised through the applicable bilateral treaty framework or, for arbitral awards, the New York Convention recognition process. In practice, this means that a creditor with a European freezing order in hand must still apply separately to a Russian arbitrazh court for equivalent Russian interim measures if it wishes to restrict the debtor's ability to deal with Russian assets. The two applications should be filed as close in time as possible to avoid the gap during which the debtor remains free to act.

Q: How does the firm coordinate with European counsel on dual-jurisdiction asset recovery matters?

A: The firm acts as Russian counsel within a coordinated dual-jurisdiction team. In cross-border asset recovery matters, this typically means: advising on Russian law requirements at the asset mapping stage; filing and managing Russian interim applications; conducting Russian court proceedings or insolvency creditor filings; and providing Russian-law analysis that European counsel can integrate into the overall case strategy. The firm does not provide advice on non-Russian law; for European proceedings, it collaborates with trusted counsel in the relevant jurisdiction. Working languages are Russian and English; the firm's fee-earners communicate directly with foreign counsel and in-house legal teams in English.

• Regulatory update: cross-border asset recovery — recent developments in Russian enforcement practice
• Foreign creditors and cross-border asset recovery in Russia: a practitioner overview
• Asset Tracing & Recovery practice

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 and recovery practice advises foreign creditors, institutional investors, and distressed asset buyers on recovering value from Russian-domiciled debtors across enforcement, insolvency, and interim-relief proceedings. Matters have spanned the Russian arbitrazh court system, the Siberian and Ural federal circuits, and cross-border coordinations involving European co-counsel. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

Changes to the rules governing access to Russia's Unified State Register of Legal Entities took effect in early 2026, altering the information landscape that foreign creditors and their advisers have relied upon when tracing assets and assessing enforcement prospects against Russian debtors. The amendments restrict which categories of information remain publicly accessible, introduce a tiered authorisation framework for third-party requesters, and modify the evidentiary status of registry-sourced extracts in enforcement proceedings. For creditors with live claims against Russian entities — or those planning to initiate proceedings — the practical consequences are immediate.

Until the amendments came into force, the Unified State Register of Legal Entities — commonly referred to by its Russian abbreviation, EGRUL — provided open access to a broad range of corporate data, including the registered address of a legal entity, the identity and passport details of its sole executive officer, the list of participants and their shareholding, the history of re-registrations and address changes, and information on pledges registered against participatory interests. This level of disclosure made EGRUL one of the most practically useful starting points for asset tracing in Russia: a creditor could establish corporate structure, identify ultimate beneficial ownership through layered searches, locate affiliated entities, and pinpoint registered assets — all without prior judicial authorisation.

The 2026 amendments introduce a two-tier access regime. The first tier, designated as open access, retains disclosure of basic registration data: the entity's legal name, OGRN registration number, date of incorporation, type of legal entity, and current registered status. The second tier, designated as restricted access, covers the categories most material to asset tracing — specifically, the identity of participants and their shareholding percentages, the full details of the sole executive officer, information on pledged participatory interests, and the history of beneficial ownership changes. Access to second-tier data now requires a documented legal interest, defined to include a party to pending or anticipated court or arbitrazh proceedings, a creditor holding an enforceable monetary obligation, a notary acting in a succession matter, or a state authority. The applicant must submit a formal request to the Federal Tax Service, accompanied by supporting documents establishing the qualifying basis, and the Service has discretion to decline requests it regards as insufficiently substantiated.

Two further changes warrant attention. First, the amendments remove the ability to obtain unrestricted bulk extracts: requests are now processed per-entity, and automated querying tools — previously used by investigative firms and tracing specialists to cross-reference large corporate networks — are no longer authorised for non-state actors. Second, extract validity periods have been shortened: an extract issued more than thirty days before the date of submission to a court or arbitrazh tribunal is now treated as stale and must be refreshed at the applicant's cost.

The changes affect any party whose asset-tracing strategy depends on EGRUL as a primary or early-stage data source. In practice, this means four groups in particular.

Foreign trade creditors holding unsecured monetary claims against Russian counterparties are the most directly affected. Under the previous regime, a creditor could complete a preliminary corporate profile of its debtor — and any associated entities — before incurring the cost of formal proceedings. That pre-litigation mapping exercise is now constrained: the most valuable data points sit behind the restricted tier, and establishing a documented legal interest requires, at minimum, evidence of a claim in existence or a pending claim notice.

Foreign institutional investors and distressed-asset purchasers conducting pre-acquisition due diligence on Russian entities face a materially different information environment. Participation structure, pledge registers, and executive identity — all previously freely searchable — now require a formal request that discloses the requester's identity and interest to the Federal Tax Service. For parties seeking to maintain confidentiality in the pre-transaction phase, this creates a strategic tension.

Law firms and investigative specialists providing tracing support to foreign litigants must revise their standard search protocols. Bulk cross-referencing tools are unavailable, and the thirty-day extract validity rule means that searches conducted during preliminary investigation may need to be re-run closer to the date of filing — adding time and cost to enforcement preparation.

Foreign courts and arbitral tribunals that previously accepted EGRUL extracts as self-authenticating corporate records should note that the tighter validity rule may affect the evidential weight of older extracts produced in cross-border proceedings. Practitioners coordinating enforcement in multiple jurisdictions should factor in the re-extraction requirement when preparing evidentiary bundles.

Creditors who delay initiating formal proceedings before gathering critical registry data risk losing the ability to establish corporate structure at the pre-litigation stage — once a debtor becomes aware of the creditor's interest, voluntary restructuring or the transfer of participatory interests to third parties can move faster than the restricted-tier request process.

For creditors with live matters or those assessing enforcement prospects against a Russian counterparty, reviewing the adequacy of existing registry data is now a near-term priority before any enforcement filing.

If you hold a claim against a Russian entity and need to establish current corporate structure or beneficial ownership — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Three immediate steps follow from the amended framework.

The first is to review the quality and currency of any existing corporate registry data. Extracts obtained more than thirty days ago are no longer admissible without re-filing, and ownership data sourced before the amendments may not reflect the post-January 2026 state of the register. Any enforcement strategy that relies on stale extracts will face procedural challenge.

The second is to establish and document the legal interest basis before making a restricted-tier request. A foreign creditor with a contractual claim should gather and organise the supporting documentation — the underlying contract, correspondence evidencing the dispute, any demand notices already served — to accompany the Federal Tax Service request. A formally inadequate request is likely to be declined, wasting time and signalling the creditor's intentions without achieving disclosure.

The third is to assess whether alternative or supplementary sources can fill the gap created by restricted EGRUL access. Russian notarial registers, pledge registers maintained by the Federal Notary Chamber, land registry data from Rosreestr, and court information systems each contain asset-relevant data that remains accessible under distinct access regimes unaffected by the 2026 EGRUL amendments. A creditor who builds a tracing strategy around multiple registries rather than EGRUL alone is both better informed and less exposed to delay.

Practitioners who wish to understand how the step-by-step procedure for a Russian corporate registry search has changed in light of the new rules may find the firm's practical guide to Russian corporate registry searches a useful companion to this update. A further discussion of how these amendments interact with the broader asset tracing framework for foreign creditors is available in the firm's analysis of Russian corporate registry searches for asset tracing.

The asset tracing and recovery practice at Vetrov & Partners advises creditors on the full sequence from pre-litigation corporate mapping through to enforcement. More information about the practice is available at Asset Tracing & Recovery.

The amended framework leaves several points unresolved, and practitioners should treat current guidance as provisional pending clarifying materials from the Federal Tax Service and, in due course, judicial interpretation.

The scope of "documented legal interest" has not been defined exhaustively in the implementing materials published to date. It remains to be seen whether a creditor who has served a pre-action demand notice but has not yet filed a claim will be treated as having a sufficient qualifying basis, or whether the Service will require evidence of filed proceedings. Early-stage creditors are advised to take a conservative position and, where possible, advance to formal claim stage before making a restricted-tier request.

The thirty-day validity rule raises a specific evidentiary question for long-running matters: how are courts to treat extracts that were valid at the time they were obtained but have expired by the time the hearing takes place? No judicial guidance has yet been issued. The safest approach is to re-obtain any extract that will be relied upon at a hearing within thirty days of the hearing date, treating this as a standard procedural step rather than an exceptional one.

Finally, the interaction between the amended EGRUL access rules and the disclosure obligations that arise in arbitrazh enforcement proceedings under Russian civil procedure has not been tested. Foreign creditors seeking to rely on registry data in support of interim measures applications — where speed is material — should obtain up-to-date extracts immediately before filing and instruct their Russian counsel to address any admissibility challenge at the outset.

To discuss how the 2026 EGRUL amendments affect your enforcement strategy — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What specifically changed about accessing Russia's corporate registry in 2026?

A: The 2026 amendments split EGRUL data into two tiers. Basic registration data — entity name, registration number, incorporation date, and current status — remains publicly accessible without restriction. A second, restricted tier now covers participant identity and shareholding, the sole executive officer's details, pledge information over participatory interests, and beneficial ownership history. Access to restricted-tier data requires a formal request to the Federal Tax Service supported by documents demonstrating a qualifying legal interest. Bulk automated querying is no longer permitted for non-state actors, and extracts used in court or arbitrazh proceedings must be no older than thirty days at the date of submission.

Q: Which foreign creditors are most affected by the restrictions?

A: The changes are most consequential for trade creditors conducting pre-litigation corporate mapping of Russian debtors, and for distressed-asset investors running due diligence on Russian entities. Both groups previously relied on unrestricted EGRUL access to establish ownership structures, identify pledged assets, and locate affiliated entities — without disclosing their interest in advance. Under the new framework, that preliminary mapping exercise requires either formal proceedings or a documented claim, which advances the creditor's timeline and signals intent earlier in the process than many enforcement strategies contemplate. Law firms providing tracing support are also affected by the removal of bulk search tools and the shortened extract validity period.

Q: What should a foreign creditor do now to protect its enforcement position?

A: A creditor with an existing or anticipated claim against a Russian entity should, as a matter of immediate priority, review whether any existing registry data it holds is still within the thirty-day validity window. Where data is stale, re-requesting extracts in advance of any filing is preferable to attempting to cure admissibility issues during proceedings. Creditors who have not yet established a documented legal interest — that is, those who have not yet served a formal demand or filed a claim — should take advice on the most efficient sequence for establishing qualifying status before making a restricted-tier request. Supplementary sources, including Rosreestr and the Federal Notary Chamber's pledge register, should be integrated into any tracing strategy at this stage.

• A practical guide to Russian corporate registry searches
• Russian corporate registry searches for asset tracing: full analysis
• Asset Tracing & Recovery — practice overview

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 and recovery practice advises foreign creditors and distressed investors on corporate registry searches, pre-litigation asset mapping, and enforcement proceedings before Russian arbitrazh courts. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

When a foreign creditor holds a judgment or arbitral award against a Russian debtor and instructs local enforcement counsel, the first practical question is almost always the same: what assets does the debtor actually hold, and where are they registered? Rosreestr — Russia's state immovable property register — has long been one of the most reliable answers to that question. In mid-2026, the Federal Bailiff Service (FSSP) issued formal guidance clarifying the procedural framework under which bailiffs may access and deploy Rosreestr data during enforcement proceedings. For foreign creditors engaged in, or contemplating, enforcement against Russian debtors, this development is worth understanding in detail.

The Rosreestr property register in Russia has always been legally accessible to enforcement authorities. Russian enforcement legislation grants bailiffs broad information-gathering powers, and Rosreestr — as the state register of rights to immovable property — falls squarely within their remit. What the FSSP guidance issued in mid-2026 appears to do is consolidate and clarify the procedural steps bailiffs are expected to follow when using Rosreestr data as an investigative instrument, rather than simply as a passive record source.

Before this guidance, the practical approach varied across regional FSSP offices. Some bailiffs requested Rosreestr extracts routinely at the outset of proceedings; others waited until a debtor's declaration of assets proved incomplete or implausible. The guidance, as understood from the published materials, establishes a more uniform standard: bailiffs are directed to query Rosreestr proactively as part of the standard asset investigation sequence, and to cross-reference the register's data against the debtor's own declarations and against information obtained from other state systems — including the Federal Tax Service database and the traffic police registry for vehicles.

This formalisation carries a concrete consequence for creditors. A debtor who previously relied on a passive or inconsistently applied system to delay disclosure of real property interests will now face a more systematic check. The guidance also addresses the treatment of rights registered under third-party names where there is a basis to suspect a nominee or transfer structure, directing bailiffs to flag such patterns and escalate where appropriate.

"

" — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

If you are initiating enforcement proceedings against a Russian debtor and need to understand how Rosreestr data can be used to locate and freeze assets — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The guidance is relevant to any creditor pursuing enforcement against a natural person or legal entity that holds, or may hold, rights to immovable property in Russia. In practice, that covers a wide range of foreign creditors: trade creditors with overdue receivables from Russian counterparties, institutional creditors holding pledge agreements over Russian real estate, and distressed-debt investors who have acquired claims against Russian debtors at a discount and are now seeking recovery.

Three categories of foreign creditor are most directly affected.

• Trade creditors with unsecured claims. For unsecured foreign creditors, the enforcement process depends almost entirely on what the bailiff can locate. A more systematic Rosreestr query increases the probability that real property held in the debtor's name — or held through structures the bailiff now has a procedural basis to investigate further — will be identified and brought within the enforcement perimeter.

• Secured creditors with real estate pledges. Where a foreign creditor holds a mortgage or pledge registered with Rosreestr, the guidance reinforces the register as the primary record of that security interest. Bailiffs who follow the new standard will cross-reference the pledge against the current registered owner, identifying any purported transfer of the encumbered asset that was effected after the pledge was registered.

• Creditors in insolvency-adjacent situations. Foreign creditors who are enforcing individual claims against a debtor that may also be insolvent face a narrower window. Under Russian insolvency legislation, preferential transfer claims may be brought for transactions completed up to three years before the bankruptcy filing — a period that creditors unfamiliar with Russian practice frequently underestimate. The formalised Rosreestr query now creates a more reliable record of when property was transferred and to whom, which supports preferential transfer analysis both inside and outside formal insolvency.

The Asset Tracing & Recovery practice at Vetrov & Partners advises foreign creditors across all three categories. For a more detailed treatment of Rosreestr as an investigative instrument, see Rosreestr property register as an investigative tool in Russia.

The principal practical implication of the FSSP guidance is that a well-prepared creditor should treat Rosreestr data not merely as a resource to be obtained after enforcement begins, but as part of the pre-enforcement investigation. This matters for two reasons.

First, a creditor who obtains a Rosreestr extract before filing an enforcement application will know whether there are encumbered or recently transferred assets that warrant interim protective measures — including an application to the court for an asset freeze prior to enforcement. Russian courts have generally been willing to grant such measures where the creditor can demonstrate a real risk of dissipation, and Rosreestr data is among the strongest evidential foundations for that showing.

Second, the guidance's cross-referencing requirement means that bailiffs will now be comparing Rosreestr data against the debtor's declarations from the outset. A creditor who has already prepared its own Rosreestr analysis will be in a stronger position to prompt the bailiff to follow up on discrepancies and to flag transfers that appear to have occurred after the claim arose. Creditors who delay initiating enforcement proceedings risk losing priority in an insolvency that may be filed unilaterally by the debtor, precisely at the point when Rosreestr transfers would come under greatest scrutiny.

The practical steps that foreign creditors should consider at this stage include: (1) obtaining an up-to-date Rosreestr extract for the debtor and, where a pledge exists, verifying the current registered status of the encumbered asset; (2) reviewing whether any transfers of property occurred after the debtor defaulted or after the claim arose; and (3) consulting Russian enforcement counsel about whether an interim asset-freeze application is warranted before commencing execution proceedings.

For a comprehensive overview of the legal framework governing these steps, see The law and practice of Rosreestr property register searches in Russia.

For in-house counsel and foreign creditors managing live enforcement matters in Russia, early legal advice on the asset-freeze process can be decisive — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The FSSP guidance, as with most regulatory instruments of this type, leaves a number of interpretive questions to be resolved by practice and, ultimately, by the courts.

The most significant open question concerns the treatment of rights held through corporate structures rather than in the debtor's own name. The guidance directs bailiffs to flag nominee patterns and escalate where appropriate, but the threshold for what constitutes a sufficient basis for escalation has not been defined with precision. In practice, this is likely to produce inconsistency across regional FSSP offices until the courts establish clearer parameters through enforcement challenges.

A second open question relates to the speed of Rosreestr responses to FSSP queries. Automated inter-agency data exchange has improved markedly under the broader Russian digital government initiative, but creditors and their counsel should not assume that real-time access is universal. In some regions and for some categories of property, manual request procedures remain in place, which introduces delays that a debtor — or a debtor's advisers — may seek to exploit.

Finally, the guidance's treatment of cross-border enforcement scenarios is limited. Where a foreign creditor is seeking to enforce a foreign arbitral award recognised by a Russian court, the same FSSP enforcement framework applies once recognition is granted, and Rosreestr data is equally accessible. The guidance does not, however, address the specific procedural position of foreign creditors who are coordinating Russian enforcement with parallel proceedings in other jurisdictions. That remains an area where bespoke legal advice is warranted.

The firm's [/matters/] section includes representative matters in which Rosreestr searches have formed part of a cross-border enforcement strategy.

• Rosreestr property register as an investigative tool in Russia
• The law and practice of Rosreestr property register searches in Russia
• Asset Tracing & Recovery — practice overview

Q: What specifically changed with the Federal Bailiff Service guidance on Rosreestr?

A: The FSSP guidance issued in mid-2026 formalises Rosreestr property register queries as a standard step in the enforcement asset-investigation sequence in Russia, rather than leaving their use to the discretion of individual bailiffs. Under the guidance, bailiffs are directed to query Rosreestr proactively at the outset of proceedings and to cross-reference the results against the debtor's own declarations and data from other state registries. The practical effect is a more uniform and systematic approach to locating immovable property across regional FSSP offices.

Q: Which foreign creditors are most affected and how?

A: The guidance is most directly relevant to three groups: unsecured trade creditors who depend on the bailiff's ability to locate assets; secured creditors holding pledges over Russian real estate, who benefit from strengthened verification of pledge registration status; and creditors in insolvency-adjacent situations, where a formalised Rosreestr record of property transfers supports preferential transfer analysis under Russian insolvency legislation. Foreign creditors who have been slow to initiate enforcement proceedings are particularly affected, as the new framework increases the probability that asset transfers effected after a claim arose will be identified.

Q: What should a foreign creditor do now to use this tool effectively?

A: The most immediate step is to obtain an up-to-date Rosreestr extract for the debtor before filing the enforcement application. This allows counsel to identify recently transferred or encumbered assets and to assess whether an interim asset-freeze application is warranted. Where property has been transferred after the claim arose, counsel should review whether a preferential transfer challenge is available under Russian insolvency legislation. Coordinating the Rosreestr analysis with any parallel proceedings in the creditor's home jurisdiction is also advisable at an early stage.

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

The firm's Asset Tracing & Recovery practice advises foreign creditors — including trade creditors, institutional lenders, and distressed-debt investors — on locating, freezing, and realising Russian assets. Instruction typically involves coordinating Rosreestr searches with enforcement applications, asset-freeze proceedings, and, where applicable, parallel insolvency or recognition proceedings. With over 1,000 matters handled since inception, the team brings direct partner involvement to every engagement and maintains regular English-language communication throughout.

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/

Following the Russian Supreme Court's clarification on court-ordered disclosure of bank account information and financial flows in enforcement proceedings, foreign creditors holding Russian judgments or pursuing asset recovery in Russia face a materially different procedural landscape than the one that prevailed before this development. The clarification, which consolidates and extends existing guidance on how tracing requests are to be processed by courts and credit institutions, has direct consequences for the speed and scope of bank account tracing available to creditors in live enforcement matters and insolvency proceedings across Russian jurisdictions.

Before the Supreme Court's clarification, the procedural mechanism for tracing bank accounts and financial flows in Russia was applied inconsistently across jurisdictions. Arbitrazh courts in commercial disputes and courts of general jurisdiction in civil enforcement matters each followed their own prevailing interpretations of what information could be compelled from credit institutions and at what stage of proceedings. Creditors — particularly foreign creditors unfamiliar with local practice — frequently encountered refusals or narrow interpretations of banking secrecy provisions that effectively shielded account information from disclosure until enforcement was already well advanced.

The clarification consolidates the approach that the better-developed circuit courts had already begun applying. It confirms, as a general interpretive position, that courts exercising enforcement jurisdiction may order credit institutions to disclose account information — including account balances, transaction histories, and details of outgoing transfers — where a creditor can demonstrate a legitimate enforcement basis. The clarification also addresses the treatment of financial flows that pass through or originate from accounts held in the name of affiliated entities, a mechanism that debtors had previously used to obscure the ultimate destination of assets.

After the clarification, the operative position is that a court-issued information request addressed to a credit institution should, as a general rule, be satisfied within the statutory timeframe without the institution invoking banking secrecy as an independent ground for refusal where a court order is in place. The clarification further signals that unexplained gaps in financial flow records — periods where asset movements cannot be reconciled against disclosed balances — may be treated as an adverse inference in related proceedings.

For creditors tracing bank accounts in Russia, this shifts the practical emphasis from overcoming institutional resistance at the disclosure stage to ensuring that the information request is properly formulated and directed at the right court.

"The clarification is, in practice, an instruction to credit institutions and lower courts to treat a valid enforcement order as sufficient authority for full financial disclosure — the question for creditors is now procedural precision, not threshold entitlement." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The clarification has direct relevance for three categories of foreign creditors active in Russia.

The first category is creditors holding a Russian arbitrazh court judgment who have not yet completed enforcement, and who have reason to believe that the debtor has moved assets through multiple accounts or structured payments via affiliated entities to reduce visible balances at the moment of the enforcement search. For these creditors, the clarification strengthens the legal basis for requesting retrospective financial flow disclosure — not merely a snapshot of current balances.

The second category is foreign creditors pursuing recognition and enforcement of a foreign arbitral award or court judgment, where the enforcement court is a Russian arbitrazh court. Once recognition is granted and enforcement proceedings are opened, the same disclosure mechanisms described in the clarification apply. Creditors in this position should treat the clarification as confirming that the post-recognition enforcement phase now carries materially more teeth than it did previously in terms of information access.

The third category is creditors participating in Russian insolvency proceedings as members of the committee of creditors, or filing claims in cases where a debtor has filed a bankruptcy petition. Insolvency practitioners in Russia have the power to obtain financial flow information as part of the asset examination process, and the clarification's consolidation of disclosure obligations reinforces the basis on which creditors can insist that the insolvency practitioner pursues full account tracing — including against affiliated and subsidiary accounts — rather than accepting a restricted scope.

For creditors who have been monitoring distressed assets in Russian corporate groups, the clarification removes one layer of procedural uncertainty that had previously made it difficult to predict whether a tracing application would succeed before a particular circuit.

Foreign creditors who delay initiating or advancing enforcement proceedings in Russia risk losing the informational advantage that timely disclosure applications provide — account balances and financial flow records may be legitimately dissipated or restructured within the statutory disclosure window if no enforcement application is pending.

If you are a foreign creditor seeking to trace bank accounts or financial flows in Russia — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The clarification creates a more favourable procedural environment for tracing bank accounts and financial flows in Russia, but it does not eliminate the need for careful application strategy. The principal steps creditors should take in light of this development are the following.

First, review the scope of any existing enforcement application to confirm that the information request is formulated to capture transaction histories and outgoing financial flows — not merely current account balances. Courts have consistently distinguished between requests for balance disclosure and requests for flow disclosure; the clarification's guidance covers both, but the formulation of the application determines what is produced.

Second, where a debtor operates through a group of affiliated entities — a common structure for larger Russian commercial groups — creditors should consider whether the tracing request can and should extend to accounts held by those affiliates. The clarification addresses affiliated-entity flows, but the procedural basis for extending a request to a non-debtor entity requires a demonstrated link between the debtor's financial flows and the affiliate's accounts. This is a fact-specific analysis that benefits from early preparation.

Third, for creditors whose enforcement is proceeding through insolvency rather than direct execution, the clarification reinforces the basis on which creditors can formally request the insolvency practitioner to expand the scope of the financial flow examination to cover the pre-insolvency period — the period during which asset movements most commonly occur. Insolvency practitioners are not required to act on every creditor request, but a formally lodged request creates a procedural record and may support a later challenge if the practitioner fails to pursue disclosure.

Fourth, foreign creditors whose claims arise from agreements governed by foreign law — but who are enforcing against Russian assets — should note that the clarification applies at the enforcement stage, which is governed by Russian procedural law regardless of the governing law of the underlying contract. The availability of disclosure is a function of Russian enforcement procedure, not of the applicable substantive law.

The full analytical framework governing tracing of financial flows in Russia is examined in our deep-dive piece Tracing Bank Accounts and Financial Flows in Russia: A Deep-Dive Analysis. For the procedural approach to navigating disclosure applications in practice, see also Navigating Bank Account Tracing in Russia: A Practitioner's Guide.

For a broader overview of the firm's work in this area, visit the Asset Tracing & Recovery practice page. Details of representative enforcement matters are available in the Matters section.

The clarification, while significant, leaves certain questions open. The most practically important is the treatment of accounts held at non-resident credit institutions — foreign banks operating under Russian licences or maintaining correspondent relationships with Russian banks — where the disclosure obligation under Russian procedural law intersects with the bank's obligations under its home jurisdiction's banking secrecy rules. Russian courts have taken varying positions on this intersection, and the clarification does not appear to provide definitive guidance for cross-border account structures.

A second open question concerns the treatment of cryptocurrency-linked financial flows. Russian law on digital financial assets has developed materially in recent years, and courts are increasingly asked to address asset tracing exercises that involve flows passing through digital asset exchange accounts or cold storage wallets. The clarification's scope appears to address traditional credit institution accounts, and it is not yet clear how its principles will be applied by lower courts to digital asset flows.

Third, the practical question of enforcement against banks that resist or delay compliance with court-issued disclosure orders — and the sanctions available to courts in that scenario — remains less fully resolved than the substantive disclosure entitlement itself. Creditors should be prepared for procedural delay even where the legal entitlement to disclosure is clear.

These open questions are areas where specialist advice is material, since the outcome of a tracing exercise may turn on how the court in the relevant circuit has been applying the clarification's guidance to these fact patterns.

Q: What specifically changed in the Russian approach to tracing bank accounts following the Supreme Court's clarification?

A: The clarification consolidates the interpretive position that a court order in enforcement proceedings is sufficient authority for full financial disclosure by a credit institution — covering account balances, transaction histories, and outgoing financial flows. Before the clarification, courts applied this principle inconsistently, with some circuits accepting banking secrecy as a ground for limiting disclosure even where an enforcement order was in place. The clarification removes this ambiguity as a general matter and also addresses the treatment of financial flows involving affiliated entities of the debtor.

Q: Which foreign creditors are most directly affected by this development?

A: Three groups of foreign creditors are most directly affected. First, creditors with existing Russian enforcement proceedings who have not yet completed the asset discovery phase — particularly where the debtor operates through affiliated entities or has structured financial flows to obscure balances. Second, foreign creditors pursuing post-recognition enforcement of foreign arbitral awards or judgments against Russian assets, who now have a stronger procedural basis for disclosure applications in the arbitrazh court. Third, creditors participating in Russian insolvency proceedings as registered claimants, who can use the clarification to support requests to the insolvency practitioner to expand the scope of financial flow examination.

Q: What should a foreign creditor do now to take advantage of this clarification?

A: Foreign creditors with active or anticipated enforcement proceedings in Russia should review the formulation of any outstanding information requests to ensure they capture financial flows and transaction histories — not only current account balances. Where the debtor is part of a corporate group, creditors should assess whether affiliated-entity flows can be included in the tracing application. For creditors whose matters are at the insolvency stage, formally lodging a request with the insolvency practitioner to expand financial flow examination is advisable. Early specialist advice on the scope and formulation of a tracing application materially affects what information is ultimately produced.

To discuss the application of this clarification to your specific enforcement position — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Tracing Bank Accounts and Financial Flows in Russia: A Deep-Dive Analysis
• Navigating Bank Account Tracing in Russia: A Practitioner's Guide
• Asset Tracing & Recovery in Russia: Practice Overview

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 and recovery practice advises foreign creditors, institutional investors, and foreign law firms acting as instructing counsel on enforcement proceedings, financial flow disclosure applications, and cross-border asset recovery in Russia. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

When a foreign creditor discovers that the assets it is pursuing in Russia have been layered through one or more shell entities — each holding little on its own — the practical question is not whether Russian law permits unwinding such structures, but how difficult that exercise has become following amendments that entered into force at the start of 2027. The amendments tighten the conditions under which Russian courts will look through nominee and intermediate holding arrangements, introduce stricter evidentiary thresholds for tracing beneficial ownership, and add a new procedural stage that creditors must complete before asset-recovery claims can be heard on the merits. For foreign creditors enforcing Russian assets and for distressed investors managing exposure to Russian-element structures, understanding what has changed — and what has not — is now a practical priority.

Before the amendments, Russian courts applied a broadly discretionary standard when determining whether to consolidate assets held by formally separate legal entities into a single enforcement pool. The controlling question was whether the entities in question shared economic substance and operated under a single directing will — a standard that experienced practitioners could work with, even if outcomes varied by circuit.

The 2027 amendments replace that discretionary standard with a three-stage test. First, the claimant must demonstrate documentary evidence of unified management: board resolutions, shared signatory authority, intercompany flows, or operational integration. Second, the court must be satisfied that the intermediate entity was incorporated or maintained specifically to obstruct enforcement — a purpose requirement that was previously inferred but is now an explicit pleading burden. Third, the claimant must show that unwinding the structure would not prejudice any third-party creditor of the intermediate entity who acted in good faith.

Each stage requires separate evidentiary filings. Courts in the Siberian and Ural circuits have so far interpreted the purpose requirement strictly, declining to treat nominal registered offices or skeleton staffing arrangements as sufficient proof without accompanying financial-flow documentation. For creditors working from foreign jurisdictions, where access to Russian corporate records is procedurally constrained, this evidential escalation is material. A matter where consolidation might previously have been achieved within a single set of enforcement proceedings may now require preliminary disclosure steps before the substantive application can be filed.

The amendments also introduce a time limit on preliminary disclosure requests: a creditor who initiates the disclosure stage but does not advance to a substantive merits application within six months will have the preliminary record struck, requiring the entire process to be restarted. For foreign creditors operating on tight cash-flow timelines or with counterparties actively dissipating assets, this procedural clock is the most consequential single change in the package.

For creditors currently pursuing asset-tracing claims in Russia, the new evidentiary framework may affect proceedings already underway. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The amendments apply to all enforcement proceedings commenced on or after 1 January 2027. Proceedings commenced before that date continue under the prior framework — a transitional provision that carries its own complexity, since creditors with partially advanced matters must now decide whether to bring any pending preliminary applications to conclusion under the old standard or whether to pause and reassess under the new one.

Foreign creditors with the highest exposure are those whose Russian counterparties operate through multi-tier holding structures with intermediate entities in Cyprus, the Netherlands, or other jurisdictions that previously offered thin nominee layers. The purpose requirement under the new test is likely to be applied most rigorously where the intermediate entity's sole apparent function was asset-holding: courts have signalled, in early commentary on the amendments, that structures predating the 2022 corporate reorganisation wave will face particular scrutiny.

Trade creditors holding unsecured claims are materially more exposed than secured creditors, who retain the ability to enforce directly against pledged assets without passing through the three-stage test. A foreign trade creditor who has been waiting for an insolvency trustee to consolidate assets into the debtor's estate — a common strategy under the previous framework — may now find that the trustee's own application faces the same heightened burden, reducing the creditor's ability to rely on intra-insolvency consolidation as a substitute for direct enforcement.

Under Russian insolvency legislation, preferential-transfer claims and asset-recovery applications by the trustee against related parties are subject to limitation periods that run from the date of the triggering transaction, not from the date of insolvency filing. Foreign creditors who assumed that these windows were effectively open during active insolvency proceedings should confirm with Russian counsel whether the new evidentiary requirements have affected the trustee's ability to advance consolidation claims within those periods — a risk that several creditors in active Siberian Federal District proceedings have only recently identified.

"Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners"

The most immediate priority for any foreign creditor with an active or anticipated asset-tracing matter in Russia is to audit the evidentiary position against the three-stage test before initiating or continuing the disclosure stage. Creditors who entered Russian enforcement proceedings under the prior discretionary standard with a relatively thin documentary record will need to assess whether that record can sustain the new purpose requirement — and, if not, whether additional disclosure can be obtained before the six-month preliminary clock begins running.

Three specific actions follow from this analysis. First, identify all intermediate entities in the target structure and map the available documentary evidence of unified management for each. Russian corporate records are publicly accessible through the state registration database, but financial-flow documentation typically requires either court-ordered disclosure or cooperation from the insolvency trustee. Second, confirm the applicable limitation periods for asset-recovery and preferential-transfer claims, taking into account both the insolvency calendar and any tolling provisions that may apply to foreign claimants. Third, assess whether the matter is better advanced as a direct enforcement action against pledged assets — where the three-stage test does not apply — or whether the consolidation route remains viable in light of the evidentiary position.

Foreign counsel coordinating Russian asset-tracing mandates should also note that the amendments affect EAEU-member creditors differently from creditors outside the EAEU. Intermediate entities incorporated in EAEU jurisdictions benefit from a modified purpose-requirement standard that treats economic integration within the EAEU as a factor weighing against the inference of obstruction — a provision that may be relevant where the shell structure includes Armenian, Kazakh, or Belarusian holding entities.

The firm's Asset Tracing & Recovery practice advises foreign creditors on the full range of Russian enforcement and consolidation proceedings. For context on the structural issues that commonly arise before enforcement, see our analysis of unwinding shell company structures with Russian elements and our comparative analysis of unwinding approaches across jurisdictions.

If you are coordinating an asset-tracing or enforcement matter with Russian elements — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The amendments leave several points unresolved that are likely to be clarified through court interpretation in the course of 2027. The most significant is the standard of proof that applies to the purpose requirement. The legislative text requires that the obstructive purpose be demonstrated — but it does not specify whether that is a balance-of-probabilities standard or a higher threshold. Courts in the Moscow circuit and in Novosibirsk have taken divergent initial positions, and guidance from the Supreme Court or the Economic Disputes Chamber is anticipated but not yet available.

A second open question concerns the treatment of restructured entities: where a shell company was genuinely restructured after the date of the creditor's claim — acquiring real assets, employees, and operational function — it is not yet clear whether the purpose requirement is assessed at the time of incorporation, at the time of the creditor's claim, or at the date of the enforcement application. This matters acutely for creditors dealing with counterparties that have used the period since 2022 to operationalise previously dormant holding entities.

For matters before the Russian courts and the distressed assets landscape, the firm will continue to track circuit-level decisions as they emerge.

• Unwinding shell company structures with Russian elements
• Comparative analysis: unwinding shell company structures across jurisdictions
• Asset Tracing & Recovery practice — Vetrov & Partners

Q: What specifically changed in Russian law regarding the unwinding of shell company structures in 2027?

A: The amendments, which entered into force on 1 January 2027, replaced the prior discretionary standard for court-ordered asset consolidation with a mandatory three-stage test. Claimants must now separately demonstrate: (i) documentary evidence of unified management across the entities in question; (ii) that the intermediate entity was incorporated or maintained specifically to obstruct enforcement; and (iii) that unwinding would not prejudice any good-faith third-party creditor of the intermediate entity. A six-month time limit applies to preliminary disclosure proceedings, after which the record is struck if no substantive application is filed. The amendments represent a material increase in the evidentiary burden for foreign creditors tracing assets through Russian-element shell structures.

Q: Which categories of foreign creditor are most affected by the 2027 amendments?

A: Foreign trade creditors holding unsecured claims against Russian counterparties operating through multi-tier holding structures face the greatest exposure, particularly where the intermediate entities are incorporated in jurisdictions — such as Cyprus or the Netherlands — that historically served thin nominee functions. Secured creditors enforcing directly against pledged assets are not subject to the three-stage test. Creditors from EAEU member states (including Armenia, Kazakhstan, and Belarus) benefit from a modified purpose-requirement standard that weighs economic integration within the EAEU against the inference of obstructive intent. Proceedings commenced before 1 January 2027 continue under the prior framework, though creditors with partially advanced matters should seek Russian counsel advice on transitional timing.

Q: What immediate steps should a foreign creditor take in light of these changes?

A: Three steps are advisable. First, audit the existing evidentiary record against the new three-stage test before initiating or continuing the disclosure stage — a record that was sufficient under the prior discretionary standard may not satisfy the purpose requirement. Second, confirm all applicable limitation periods for asset-recovery and preferential-transfer claims, as the six-month preliminary clock interacts with insolvency timelines in ways that vary by matter. Third, assess whether the enforcement posture should be recalibrated toward direct enforcement against pledged assets, where the three-stage test does not apply. Foreign counsel coordinating these mandates should initiate early contact with Russian lawyers given the procedural sequencing that the new framework imposes.

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 insolvency practitioners on the identification, tracing, and enforcement of Russian-element assets. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of Russian enforcement and insolvency proceedings with direct partner involvement on every engagement. The Siberian Federal District location provides proximity to Siberian and Ural circuit courts, which handle a disproportionate share of distressed-asset and enforcement matters involving industrial-sector counterparties.

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/

When a foreign creditor holding a claim secured through a Cyprus-Russia corporate structure attempts enforcement in Russia today, the landscape it encounters differs materially from the one its advisers mapped in 2021. The Federal Bailiff Service (FBS) has, across 2022 to 2027, developed enforcement patterns that have progressively eroded the practical utility of Cyprus-Russia corporate structures as a buffer between creditor and Russian assets. For foreign creditors in distressed situations — whether holding pledges over Russian subsidiaries, inter-company loan receivables, or equity stakes in Russian operating companies held through Cypriot intermediate vehicles — the shift is consequential and, in several respects, is still evolving. This update sets out what has changed, who is most affected, and what recovery strategies remain available under current Russian law.

Before 2022, the Cyprus-Russia corporate structure was, for many international investors, a settled and largely predictable legal architecture. The bilateral investment treaty between Cyprus and the Russian Federation — now suspended as between the two states — provided a framework of investor protections that, while never absolute, constrained the most aggressive forms of Russian enforcement action. Cypriot intermediate holding companies sat above Russian operating subsidiaries as a recognised insulation layer: Russian courts and bailiff authorities acknowledged the corporate veil and proceeded against Russian-domiciled assets through Russian-law enforcement mechanisms without routinely pursuing upstream consolidation.

That position has shifted substantially. From 2022 onwards, Russian regulatory and judicial attitudes towards Cyprus-Russia corporate structures underwent a realignment driven by several concurrent developments: the suspension of the double taxation treaty between Russia and Cyprus (effective August 2023), the broader legislative framework governing the exit of foreign shareholders from strategic sectors, and amendments to civil procedure rules governing the enforcement of claims where intermediate foreign holding structures are involved. Each of these, individually, would have required adjustment from foreign creditors. In combination, they have produced a materially different enforcement environment.

The FBS, as the body responsible for executing court judgments and enforcement titles in Russia, has adapted its operational approach accordingly. Enforcement officers now more routinely examine the chain of ownership above the Russian obligor when executing against shares, participatory interests, or rights flowing from inter-company arrangements. Where the immediate shareholder or creditor is a Cypriot entity, FBS practice in a number of circuits — particularly in Moscow and, increasingly, in the Siberian and Ural regions — has shifted towards treating the Cypriot layer as potentially transparent for purposes of identifying assets available to satisfy enforcement titles. This is not a uniform or fully codified position: courts in different circuits have approached the question differently, and the legal basis for structural transparency in enforcement proceedings remains contested in Russian doctrine.

Critically, the FBS has also adopted a more active posture with respect to asset freezes. Foreign creditors who have obtained enforcement titles — whether through Russian arbitrazh courts, MKAS arbitration, or by recognition of foreign awards — are finding that the freeze mechanisms available to them against Russian-domiciled assets are both more accessible and more aggressively competed for by Russian domestic creditors than was the case five years ago. Timing of enforcement action, always important, has become a first-order variable.

Not all foreign creditors with Cyprus-Russia exposure are equally affected. Exposure is highest along two axes: the position of the Cypriot vehicle in the credit structure, and the sector and regulatory classification of the Russian operating assets.

Creditors whose claims are held directly by a Cypriot entity — as opposed to through a Russian-registered branch or subsidiary with its own Russian-law security package — face the greatest structural uncertainty. Where the enforcement title will be sought in Russia based on a foreign award or a foreign-law governed contract, the recognition procedure adds a procedural layer that domestic Russian creditors do not face. The window between recognition and effective asset freeze has narrowed in practice: competing enforcement actions, insolvency filings by the Russian obligor, and regulatory interventions affecting strategically classified assets can all intervene within that window.

Creditors secured by pledges over shares in Russian operating companies face a specific difficulty where the pledgor is the Cypriot holding vehicle rather than a Russian-domiciled entity. The enforcement of pledges over participatory interests in Russian limited liability companies has its own procedural sequence under Russian civil and corporate law, and where the pledgor's capacity to perform or consent is complicated by Cypriot corporate restrictions, insolvency, or the absence of authorised representatives in Russia, that sequence can stall.

"The structural assumptions embedded in pre-2022 Cyprus-Russia lending arrangements now require methodical reassessment — not because the legal routes to enforcement are closed, but because the procedural sequencing and the timing of each step have become far more consequential than they were." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

Foreign creditors in the energy, telecommunications, and logistics sectors face additional complexity arising from regulatory classification of their Russian counterparties' assets. Enforcement against assets in these sectors increasingly intersects with authorisation requirements outside the standard FBS execution framework.

The practical consequence — and a risk that foreign creditors under time pressure from their own capital or reporting obligations frequently underestimate — is that the window for securing a senior enforcement position over Russian assets may be measured in weeks rather than months from the point at which the Russian obligor's financial distress becomes apparent. Under Russian insolvency legislation, transactions that could be characterised as providing preferential security or as undervalued disposals may be challenged for transactions completed in the three years preceding a bankruptcy filing. Creditors who act late not only risk losing priority to domestic creditors who move faster: they risk having their security unwound entirely.

If you hold a claim secured through a Cyprus-Russia corporate structure and are assessing your recovery position, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The answer depends on where in the enforcement cycle the creditor sits. For creditors who have not yet initiated proceedings, the priority is structural assessment: mapping the chain of ownership, identifying which assets are Russian-domiciled, determining whether existing security documents create enforceable Russian-law rights or whether enforcement will require a foreign award followed by Russian recognition, and — critically — assessing the current solvency position of the Russian obligor.

For creditors who have already obtained an enforcement title, or who are in the final stages of Russian court or arbitration proceedings, the focus shifts to execution strategy. This means working with Russian counsel to identify available freeze mechanisms, understanding the FBS circuit in which assets are located (circuit practice varies), and determining whether a voluntary enforcement procedure or an immediate FBS application is likely to produce a faster and more durable result.

Several practical steps merit priority attention regardless of where in the cycle a foreign creditor sits.

First, the Cypriot intermediate vehicle's standing to act in Russian proceedings should be verified now, before proceedings commence. Cypriot entities operating under restrictions imposed by Cypriot regulators, or whose directors have resigned or been replaced, may lack the authorisation to instruct Russian counsel, file claims, or execute security documents. These are not hypothetical risks: the firm has encountered this configuration in recent matters.

Second, the documentation package underlying the credit arrangement should be reviewed for Russian-law adequacy. Facilities governed by English or other foreign law are enforceable in Russia through the recognition procedure, but that procedure adds time and creates an opportunity for the obligor to take defensive steps. Where Russian-law governed security documents exist alongside the facility agreement, their adequacy under current Russian law — which has changed in material respects since 2022 — warrants fresh review.

Third, foreign creditors should understand the regulatory classification of the Russian obligor's principal assets. Enforcement against assets subject to special regulatory regimes may require additional governmental or regulatory approvals, and the timeline for obtaining those approvals can extend well beyond the standard FBS execution timeframe.

The firm's Asset Tracing & Recovery practice has acted for foreign creditors in a number of recent matters involving Cyprus-Russia structures, including creditors whose enforcement positions had been prejudiced by delays in acting on the structural changes described in this update. For analysis of how Russian courts approach the corporate veil question in enforcement proceedings, see How Russian courts approach Cyprus-Russia corporate structures. For strategic planning considerations in live enforcement situations, see Strategic considerations in Cyprus-Russia corporate enforcement.

To assess your enforcement position against a Cyprus-Russia structure, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• How Russian courts approach Cyprus-Russia corporate structures
• Strategic considerations in Cyprus-Russia corporate enforcement
• Foreign creditor enforcement in Russian insolvency proceedings

Q: What specifically changed in FBS enforcement practice against Cyprus-Russia structures after 2022?

A: The most significant practical change is that the Federal Bailiff Service has adopted a more active approach to looking through Cypriot intermediate vehicles when identifying assets available to satisfy enforcement titles in Russia. Before 2022, the corporate separation between a Cypriot holding company and its Russian subsidiary was treated as largely settled by enforcement authorities. Since 2022, a combination of treaty suspension, regulatory amendments, and shifts in judicial attitude has made that separation less reliable in practice. The position is not uniform across Russian circuits, and the legal doctrine supporting structural transparency in enforcement remains contested — but foreign creditors who assume the pre-2022 framework still operates are taking a risk that is no longer justified.

Q: Which types of foreign creditor are most affected by the changes in FBS enforcement practice?

A: Foreign creditors most affected are those whose claims are held directly by a Cypriot entity rather than a Russian-registered vehicle, those relying on foreign-law governed documents whose enforcement in Russia requires recognition proceedings, and those holding pledges over shares or participatory interests in Russian companies where the pledgor is Cypriot-domiciled. Creditors with exposure to assets in regulated sectors — energy, telecommunications, logistics — face additional complexity arising from sector-specific authorisation requirements that operate alongside the standard FBS execution framework. In all cases, the critical variable is timing: the window between the first signs of obligor distress and a sustainable senior enforcement position has shortened materially since 2022.

Q: What practical steps should foreign creditors take immediately?

A: Three steps should be prioritised. First, verify that the Cypriot intermediate vehicle has the legal capacity to instruct Russian counsel and act in Russian proceedings — director resignations, regulatory restrictions, or corporate incapacity on the Cypriot side can stall enforcement before it begins. Second, review the Russian-law adequacy of existing security documents, since Russian law has changed materially since 2022 and documents adequate at the time of the original transaction may require updating or supplementation. Third, assess the current regulatory classification of the Russian obligor's assets, since enforcement against assets in regulated sectors may require approvals that extend the timeline significantly beyond standard FBS execution periods. Engaging Russian counsel with direct FBS enforcement experience at the assessment stage — before proceeding to the execution phase — is the practical priority.

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 — including trade creditors, institutional investors, and distressed debt holders — on the enforcement of claims against Russian-domiciled assets and Russian operating companies held through intermediate foreign structures. The team covers the full enforcement cycle: from structural analysis and pre-litigation positioning through to FBS execution, recognition of foreign awards, and insolvency creditor proceedings in the Siberian and Ural federal districts. With over 1,000 matters handled since inception, the practice combines procedural depth with direct partner involvement, and benefits from a UTC+7 working day that creates effective overlap with both European and Asia-Pacific creditor teams.

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/

Foreign creditors holding valid Russian judgments or arbitral awards against Russian nationals who own UAE real estate are encountering a materially changed enforcement environment. Over the past two years, Russian regulatory developments — spanning foreign currency controls, mandatory asset disclosure obligations, and restrictions on cross-border capital flows — have altered how UAE property held by Russian nationals is characterised under Russian law and, consequently, how foreign creditors may pursue it. This update sets out what changed, who is most directly affected, and what steps creditors should take now to protect their recovery position.

Until recently, UAE real estate held by Russian nationals occupied a relatively opaque corner of Russian asset disclosure and enforcement practice. Russian law has always required residents to disclose foreign bank accounts; the parallel obligation to disclose and report on the ownership of foreign real estate and foreign corporate structures holding such property has been tightened incrementally since 2022 and, under the prevailing interpretation by the Federal Tax Service and the Central Bank of Russia, now extends to a broader category of property rights and beneficial interests than was previously enforced in practice.

The key shift is not a single legislative act but a convergence of regulatory pressure across three channels. First, Russian currency legislation — which governs transactions by Russian residents in foreign jurisdictions — has been interpreted by enforcement authorities to treat the receipt of proceeds from UAE real estate (rental income, sale proceeds) as a controlled foreign-currency transaction. Where a Russian national receives such proceeds into a UAE account without repatriation, the currency control regime may characterise this as a violation, creating a liability that a creditor can engage with in Russian proceedings. Second, the Federal Tax Service has substantially increased its cross-border information exchange activity with Gulf jurisdictions, including under bilateral cooperation frameworks that are not full tax treaties. The practical effect is that UAE property registered in the name of a Russian national — or held through a UAE company with a Russian beneficial owner — is increasingly visible to Russian authorities and, by extension, to creditors pursuing enforcement in Russia. Third, Russian insolvency and enforcement procedure now incorporates a broader judicial discretion to recognise and engage with foreign assets in the context of bankruptcy proceedings and personal liability claims against controlling persons of insolvent entities. Courts in several circuits have accepted UAE real estate valuations as part of asset schedules in personal bankruptcy matters, even where title is held offshore.

The cumulative result is that UAE real estate owned by Russian nationals is less sheltered from Russian enforcement proceedings than it was three years ago — but the path to recovery remains indirect, jurisdiction-specific, and dependent on the particular structure through which the property is held.

"In practice, the question is rarely whether UAE property can be identified — it frequently can — but whether the enforcement sequence is structured to convert identification into recovery before the asset is transferred or encumbered." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The regulatory changes described above affect creditors in different ways depending on the nature of their claim and the forum in which they hold an enforceable instrument.

Foreign trade creditors with a Russian court judgment are in a relatively direct enforcement position. A Russian court judgment — whether from a court of general jurisdiction or an arbitrazh court — can be applied to Russian proceedings that include a UAE asset schedule, provided the asset is disclosed or established through evidence. The enforcement officer or trustee in a personal bankruptcy matter has procedural tools to compel asset disclosure and to challenge transfers made within the look-back periods applicable under Russian insolvency legislation. For trade creditors who have not yet brought Russian proceedings but hold a foreign judgment or arbitral award, the recognition question is prior — and that step should not be deferred.

Foreign institutional creditors and distressed investors holding claims through offshore SPVs face a more layered problem. Where the claim itself is held through a Cypriot, Dutch, or similar structure, the standing question in Russian proceedings requires analysis before enforcement strategy is set. The structural position of the creditor affects both the recognition of the claim and the creditor's ability to participate in asset realisation proceedings. In the current Russian legal environment, creditors whose claims are routed through jurisdictions that have suspended double tax treaties with Russia face additional procedural friction — not necessarily a bar, but a source of delay that narrows the effective recovery window.

HNWI advisers and foreign insolvency practitioners acting for creditors in third-country proceedings should note that Russian personal bankruptcy law provides for cross-border recognition in limited circumstances. The standard is not reciprocity in the English-law sense; Russian courts assess recognition on a case-by-case basis, and the outcome is less predictable than in UNCITRAL Model Law jurisdictions. The practical implication is that coordination with Russian counsel should occur at the point when the international proceeding is still open, not after it has concluded.

If you hold a judgment, award, or trade claim against a Russian national and have reason to believe UAE property forms part of their asset base — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The regulatory developments described above open enforcement angles that were not reliably available before — but they also impose time constraints. Two dynamics create urgency without alarm: first, the look-back periods under Russian insolvency legislation for preferential and undervalue transfers are not unlimited. Creditors who delay initiating enforcement proceedings risk losing the ability to challenge asset transfers that may already be in motion. Second, the UAE's own regulatory posture has been evolving: enhanced beneficial ownership registers, mandatory disclosure of ultimate beneficial owners in free zones, and increased responsiveness to foreign regulatory inquiries all mean that the window during which a Russian national can restructure UAE property ownership to frustrate a creditor is narrowing — but it has not closed.

The practical sequence for most ICP-4 creditors is as follows. First, establish whether an enforceable instrument exists in a form that Russian courts can recognise. For foreign arbitral awards, this means confirmation of the award's status under the New York Convention framework and readiness to file a recognition application in the relevant Russian arbitrazh court. Second, commission a targeted asset tracing exercise focused on UAE property registries, free zone company registers, and publicly available disclosure filings. The output of this exercise determines whether a freezing application or interim relief in parallel proceedings is viable. Third, assess the insolvency position of the Russian national. If the debtor is at or near insolvency, creditor-initiated bankruptcy proceedings in Russia may offer a more effective enforcement path than individual execution, particularly where the UAE asset is the primary recoverable item.

For creditors with a Russian arbitral award from MKAS or the Russian Arbitration Centre, enforcement through the arbitrazh court system is procedurally well-trodden, and the inclusion of foreign assets in the enforcement scope is a developed — if not uniform — area of practice across the Siberian and Ural circuits.

For a structured review of your enforcement options against a Russian national holding UAE real estate — request our practice review: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Several significant uncertainties remain, and creditors should approach any enforcement strategy with these in mind.

The treatment of UAE freehold property held in the debtor's own name — as opposed to property held through a UAE company — is not uniformly addressed across Russian circuit courts. The Siberian circuit and the Moscow circuit have reached materially similar conclusions on the inclusion of such property in personal bankruptcy asset schedules, but the evidentiary standard for establishing current ownership, current encumbrances, and current market value remains court-specific. Creditors should not assume that a UAE title certificate alone will satisfy a Russian court's evidential requirements.

The interaction between UAE freezing orders (obtained from UAE courts or DIFC/ADGM arbitral bodies) and Russian enforcement proceedings is not governed by any bilateral enforcement treaty. A UAE interim order does not automatically prevent disposition of the asset in the UAE; it depends on UAE court jurisdiction and service. Parallel proceedings in both jurisdictions require careful sequencing to avoid procedural conflicts that could undermine both tracks.

Finally, the question of Russian capital control approvals — whether a Russian national resident is required to obtain a permit from the Central Bank of Russia to transfer proceeds from the sale of foreign real estate — affects the debtor's own legal position but also creates a potential avenue for creditors. Where a debtor has received UAE property sale proceeds without the required regulatory approval, that fact may be relevant to asset-concealment arguments in Russian insolvency proceedings. The applicable regulatory position here has been subject to interpretation and guidance that, as of mid-2027, has not been fully settled by binding court practice.

Q: What specifically changed in Russian law that affects UAE real estate owned by Russian nationals?

A: No single statute has redefined the position, but three overlapping regulatory developments have shifted the enforcement landscape materially. Russian currency legislation has been interpreted to treat UAE rental income and sale proceeds as controlled foreign-currency transactions where funds are not repatriated. The Federal Tax Service has significantly increased its information-exchange activity with Gulf jurisdictions, bringing UAE property into clearer regulatory visibility. And Russian insolvency courts have broadened their practical approach to foreign assets in personal bankruptcy proceedings, accepting UAE real estate as part of debtor asset schedules in a growing number of matters. Together, these changes mean that UAE property is less shielded from Russian enforcement proceedings than it was three years ago.

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

A: Foreign trade creditors with a Russian court judgment or an enforceable arbitral award are in the most direct position to benefit from these changes, since Russian enforcement tools — including personal bankruptcy proceedings — now reach UAE assets more reliably. Institutional creditors holding claims through offshore structures face additional standing and recognition questions that must be resolved before enforcement strategy is deployed. Foreign insolvency practitioners coordinating international proceedings should engage Russian counsel early, before the Russian-side proceedings conclude, to preserve cross-border coordination options.

Q: What should a foreign creditor do if they suspect a Russian debtor holds UAE real estate?

A: The immediate priority is to establish whether an enforceable instrument — a Russian court judgment, a recognised foreign arbitral award, or an MKAS/RAC award in enforcement — is in place or obtainable. In parallel, a targeted asset tracing exercise across UAE property registries and free zone company registers will determine whether interim relief or freezing applications are viable. Creditors should also assess the debtor's insolvency position: where the debtor is at or near insolvency, creditor-initiated Russian bankruptcy proceedings may offer a more effective path to UAE asset realisation than individual execution alone.

• Foreign creditors and UAE real estate owned by Russian nationals
• Anatomy of UAE real estate owned by Russian nationals: a creditor's guide
• Asset Tracing & Recovery

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 and recovery practice advises foreign creditors, distressed investors, and international insolvency practitioners on the identification, tracing, and enforcement of assets held by Russian nationals and Russian entities — including assets held through offshore and foreign structures. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of Russian enforcement and insolvency law with 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/

When a foreign creditor holds a judgment or arbitral award against a Russian counterparty and simultaneously pursues assets across two or more jurisdictions, the practical question has always been how to sequence and coordinate those proceedings without inadvertently surrendering claims or creating procedural conflicts. Until recently, Russian court practice on this question was permissive but largely unpredictable. A discernible shift has emerged over the past year in how Russian arbitrazh courts approach requests to coordinate enforcement steps with ongoing foreign proceedings — and the consequences for distressed assets held in Russia are material for creditors who have not adjusted their strategy.

The shift is best understood as a movement from informal tolerance to structured scrutiny. Previously, foreign creditors pursuing distressed Russian assets could, in practice, advance parallel proceedings in Russian courts and foreign jurisdictions with limited obligation to disclose the full picture of concurrent enforcement activity. Russian courts were not systematically inquiring into whether a creditor seeking asset-tracing orders or enforcement measures in Russia was simultaneously pursuing equivalent relief elsewhere.

The emerging approach is materially different. Russian arbitrazh courts — particularly at the appellate and cassation levels — have begun applying closer examination to applications where the applicant is also a party to active foreign enforcement proceedings touching the same debtor or the same asset pool. Courts have shown a heightened interest in whether the relief sought in Russia is genuinely complementary to the foreign proceedings or whether it duplicates measures already in place elsewhere. In several instances, courts have required creditors to provide a structured account of all live enforcement steps across jurisdictions before granting further interim or enforcement relief in Russia.

This is not a codified procedural reform with a single effective date. It is an evolution in judicial culture — one that has built up across decisions at multiple circuit levels and has become consistent enough to treat as the prevailing approach in contested enforcement matters. For creditors coordinating enforcement across Russia and foreign jurisdictions, the practical effect is that transparency about the global enforcement picture is no longer optional: it is becoming a threshold condition for obtaining Russian relief.

"The shift we are observing is not about courts becoming hostile to foreign creditors — it is about courts requiring a coherent enforcement narrative. Creditors who present a structured cross-border strategy are receiving more, not less, cooperation from Russian courts." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign creditors assessing how this shift affects live proceedings — coordinating enforcement across Russia requires a clear strategy for each forum. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The change in approach is not uniform in its impact. Its weight falls most heavily on creditors operating in the following circumstances.

Creditors holding distressed Russian assets alongside foreign-jurisdiction security or guarantees are the primary group. Where a creditor has, for instance, a pledge over Russian real estate or equipment and a concurrent claim under a foreign guarantee or corporate undertaking, Russian courts are now more likely to examine how the Russian enforcement step interacts with the foreign security enforcement — and whether the Russian relief is calibrated to the creditor's net exposure rather than gross claim.

Cross-border enforcement involving EAEU member states presents a distinct configuration. The Eurasian Economic Union framework provides for recognition and enforcement of member-state court decisions under treaty arrangements that operate differently from the New York Convention route used for foreign arbitral awards. Creditors who trace assets Russia-side while simultaneously pursuing recognition of an EAEU-jurisdiction judgment are now navigating a space where Russian courts have shown particular interest in ensuring the two tracks are not producing double recovery. The standard of disclosure expected in EAEU-connected matters appears to be converging with the higher standard that courts were already applying in matters involving Western-jurisdiction proceedings.

CIS-connected enforcement — particularly where the debtor has assets across multiple former Soviet jurisdictions — is subject to the same trend. Creditors relying on the 1992 Minsk Convention framework for recognition of CIS court decisions will encounter the same expectation of transparency about parallel steps.

Foreign trade creditors with Russian distributor or subsidiary counterparties — a significant portion of the firms that approach Vetrov & Partners for asset tracing and recovery advice — face a specific risk: the assumption that Russian and foreign enforcement tracks can run independently, managed by separate counsel without a coordinated disclosure position, is no longer a safe one. Creditors who delay consolidating their cross-border enforcement strategy risk having Russian court applications adjourned or declined pending fuller disclosure of concurrent foreign proceedings.

The practical implication of this shift is that the enforcement brief needs to be conceived as a single cross-border matter from the outset — not as a series of parallel national matters. That has always been the technically correct approach; it is now also the procedurally necessary one in Russia.

Three immediate steps are worth identifying.

First, creditors with live enforcement proceedings in Russia and at least one other jurisdiction should conduct an audit of how those proceedings have been disclosed to each forum. If the Russian court file does not contain an up-to-date account of parallel foreign steps, the creditor's position is exposed. Russian courts are capable of requesting this information on their own motion, and an incomplete disclosure at that stage is more damaging than a proactive, structured filing.

Second, creditors planning new enforcement steps in Russia — whether interim measures, asset-tracing orders, or execution on an existing judgment or arbitral award — should prepare a coordinated enforcement narrative before filing. This does not require disclosing confidential litigation strategy, but it does require presenting the Russian proceedings as part of a coherent global recovery effort. Legal teams managing the Russian file and the foreign file need to be briefed jointly, not in isolation.

Third, creditors whose Russian counterparties have material assets in EAEU or CIS jurisdictions should revisit whether the treaty-recognition route in those jurisdictions has been properly mapped into the Russian enforcement strategy. The interaction between the treaty frameworks and the emerging Russian court practice on coordination is an area where the analysis is still developing, and decisions made now about sequencing will affect options later.

For creditors in live proceedings, the margin for uncoordinated action has narrowed. The Asset Tracing & Recovery practice at Vetrov & Partners advises foreign creditors on structuring enforcement across Russian and foreign forums, including preparation of coordinated disclosure strategies for Russian court applications. Further analysis of the risk points in this area is available at Key risk points in coordinating enforcement across jurisdictions and Coordinating enforcement across Russia and foreign jurisdictions.

If your recovery strategy involves distressed Russian assets alongside enforcement steps in other jurisdictions — speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Key risk points in coordinating enforcement across jurisdictions
• Coordinating enforcement across Russia and foreign jurisdictions
• Asset tracing and recovery in Russia: an overview

Q: What specifically changed in Russian court practice on cross-border enforcement coordination?

A: Russian arbitrazh courts — at appellate and cassation level — have moved from tolerating undisclosed parallel foreign proceedings to actively scrutinising them. The emerging practice requires foreign creditors to provide a structured account of all live enforcement steps in other jurisdictions before Russian courts will grant further relief in Russia. This is a shift in judicial culture, not a codified statutory reform, but it is now consistent enough across circuit-level decisions to treat as the prevailing standard in contested enforcement matters.

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

A: The shift affects most acutely those creditors coordinating enforcement across Russia and at least one other jurisdiction simultaneously — including those pursuing EAEU or CIS treaty-recognition tracks alongside Russian court proceedings. The core risk is that an application for Russian interim measures or enforcement relief, made without adequate disclosure of concurrent foreign steps, may be adjourned or declined. Creditors holding security in Russia alongside guarantees or pledges governed by foreign law, and those with distressed Russian assets as part of a wider recovery portfolio, should treat integrated cross-border disclosure as a threshold requirement, not an optional supplement to their Russian filing.

Q: What is the recommended immediate action for creditors with live Russian enforcement proceedings?

A: Three steps are advisable. First, audit what has already been disclosed to the Russian court about parallel foreign proceedings and remedy any gap proactively before the court raises it on its own motion. Second, prepare a coordinated enforcement narrative — presenting the Russian proceedings as part of a structured global recovery strategy — before any new filing. Third, ensure that legal counsel managing the Russian file and foreign files are briefed jointly and have a shared understanding of disclosure obligations across each forum. Early coordination is materially less costly than corrective action after a Russian court has raised the absence of disclosure.

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 and recovery practice advises foreign creditors — including trade creditors, institutional lenders, and distressed-asset investors — on locating and enforcing against Russian-located assets, coordinating cross-border enforcement strategies, and navigating Russian court procedure from interim measures through to execution. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of the Russian arbitrazh system with 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/

For a foreign creditor who has obtained a worldwide freezing order from an English, Dutch, or other European court, the question of how that order reaches Russian-situated assets has grown materially more complex in the opening months of 2026. Russian courts do not give automatic effect to foreign interim measures, and the procedural routes for achieving the functional equivalent of a freeze over Russian assets have continued to evolve — sometimes in directions that close previously available options, sometimes in ways that open new ones. This analysis sets out the principal developments, their practical significance for foreign creditors, and the steps that experienced practitioners would prioritise at this stage.

The central legal position has not shifted: Russia is not a party to any multilateral convention that provides for the direct enforcement of foreign interim relief, and Russian procedural law does not recognise a foreign freezing order as an executable instrument in its own right. What has evolved in early 2026 is judicial practice on two adjacent questions — both of which matter significantly to foreign creditors with Russian-situated assets.

First, Russian arbitrazh courts have continued to develop their approach to domestically-granted interim measures sought in parallel to, or in support of, foreign arbitration proceedings. The prevailing approach across a number of circuit courts is to treat a valid arbitration agreement as a relevant factor — though not a determinative one — when assessing whether to grant interim relief over Russian assets. Creditors who can demonstrate both an arbitration clause and a prima facie arguable claim have, in the majority of cases reviewed by the firm, encountered a more receptive judicial environment than those relying solely on a pending foreign court action.

Second, and of greater concern to foreign trade creditors, is the continued tightening of procedural requirements around the security that a claimant must lodge when seeking an interim measure in Russian proceedings. In the past twelve months, courts in several circuits have applied a stricter proportionality test — requiring creditors to demonstrate that the measure sought is calibrated to the specific asset at risk, not simply to the maximum value of the claim. The practical effect is that broad-form freezes, which more closely resemble a conventional worldwide freezing order, are encountering more rigorous judicial scrutiny than targeted asset-specific measures.

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If you hold a worldwide freezing order and are assessing its reach over Russian-situated assets, make an enquiry with our asset tracing and recovery team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The developments described above have uneven impact across creditor types, and the distinction matters when planning enforcement strategy.

Trade creditors holding unsecured claims are most exposed. Without a proprietary or security interest in identified Russian assets, the route to effective interim relief runs through the Russian courts' interim measures jurisdiction — which, as described, has become more exacting. For this group, the risk of delay between obtaining a foreign order and achieving any practical hold over Russian assets has increased. Foreign creditors who delay initiating parallel Russian proceedings risk the debtor dissipating, transferring, or restructuring its Russian asset base before any domestic measure is in place — a window that Russian insolvency law can close once a bankruptcy petition is filed, but only if the creditor is already engaged in those proceedings.

Secured creditors — those holding a pledge or mortgage over specific Russian-situated assets — occupy a different position. Their enforcement rights are governed by the terms of the security instrument and Russian property law, and they are generally not dependent on the worldwide freezing order regime to preserve their position. The principal risk for this group lies in insolvency proceedings overtaking their enforcement timeline, which makes early engagement with Russian counsel a structural necessity rather than a precautionary step.

Institutional creditors and distressed-debt purchasers, who often acquire claims after the debtor's difficulties are already apparent, face the most compressed timelines. By the time a worldwide freezing order is obtained in a foreign court, Russian-situated assets may already be subject to competing claims, pending insolvency proceedings, or prior-ranking security. The practical guidance for this group is addressed in the section below.

For those navigating the broader restructuring and insolvency landscape, the firm's Restructuring & Insolvency practice provides a complementary analysis of how creditor rights are prioritised once Russian insolvency proceedings have commenced. The firm's Asset Tracing & Recovery practice sets out the full procedural framework.

Three procedural priorities emerge from the current landscape, each addressing a distinct risk point.

The first priority is establishing a parallel Russian proceedings track as early as possible. Foreign creditors who have obtained or are seeking a worldwide freezing order should simultaneously assess whether a claim can be filed in the competent Russian arbitrazh court or whether the arbitration agreement permits a parallel domestic interim measures application. The procedural clock in Russian proceedings does not pause while foreign proceedings continue, and courts have in practice denied late-stage interim applications where the creditor could demonstrably have applied earlier.

The second priority is asset identification. A worldwide freezing order without a clear picture of the Russian asset landscape is an instrument of limited practical value in the Russian context. Russian corporate registries, land registries, and court databases provide meaningful information, though access routes for foreign creditors are more constrained than for domestic claimants. Early-stage asset tracing — before proceedings are filed and before the debtor has notice of foreign proceedings — is materially more productive than retrospective investigation. Practitioners advising on this step will wish to consult the firm's practical guide to worldwide freezing orders and the detailed analysis of the law and practice of worldwide freezing orders in the Russian context.

The third priority is security calibration. Given the stricter proportionality approach now applied by Russian courts, the application for interim relief should be constructed around identified specific assets — real property, participatory interests in Russian entities, bank account claims — rather than as a global measure. Broad-form applications are not unavailable, but they face a higher evidentiary burden and are more frequently modified or refused at the interim stage. Counsel preparing a Russian interim measures application should be in a position to identify the specific assets sought to be frozen and to justify the measure's scope relative to the quantum of the underlying claim.

Foreign creditors who have not yet reviewed their enforcement position against these developments should be aware that Russian asset dissipation — whether through voluntary transfer, corporate restructuring, or the onset of insolvency proceedings — may occur faster than the timeline required to obtain and domesticate a foreign order. Creditors are well advised to treat their Russian enforcement plan as a live operational file, not a contingency.

To discuss your enforcement strategy in relation to Russian-situated assets, contact the team for an initial 30-minute meeting — complimentary: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

"The structural gap between a foreign freezing order and effective control over Russian-situated assets has not closed — but the procedural tools for bridging it have become more specific. A targeted, asset-by-asset approach to Russian interim relief now consistently outperforms broad-form applications." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

• A practical guide to worldwide freezing orders and Russian assets
• The law and practice of worldwide freezing orders in the Russian context
• Asset tracing and recovery in Russia: an overview for foreign creditors

Q: What specifically changed in early 2026 regarding worldwide freezing orders and Russian-situated assets?

A: Russian courts have not adopted a new statute recognising foreign freezing orders in this period. What has developed is judicial practice in two respects: a somewhat more receptive approach to domestic interim measures in arbitration-related proceedings, and a stricter proportionality test applied to the scope of interim relief sought over Russian assets. The net effect is that broad-form applications face greater scrutiny, while targeted, asset-specific applications aligned with a valid arbitration agreement have a more defined — though not guaranteed — path through the Russian courts.

Q: Which types of foreign creditors are most affected by these developments?

A: Unsecured trade creditors are most exposed: they have no proprietary right to identified assets and must rely on the Russian interim measures jurisdiction, which has become more demanding. Secured creditors with pledges over specific Russian assets are less affected by the freezing order regime but must still monitor the insolvency risk to their enforcement timeline. Distressed-debt purchasers face the most compressed windows, given that by the time they acquire a claim, Russian asset movements may already be under way.

Q: What is the most practical step a foreign creditor should take immediately?

A: The most productive immediate step is to instruct Russian counsel to conduct a preliminary asset identification exercise over the debtor's Russian-situated assets — before any proceedings are filed and before the debtor has notice of enforcement activity. Simultaneously, counsel should assess whether the contractual or factual basis of the claim supports a parallel Russian interim measures application, and whether the arbitration clause — if any — permits that application to be filed in a Russian court rather than deferred to the arbitral tribunal.

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.

The firm's Asset Tracing & Recovery practice advises foreign creditors, institutional investors, and distressed-debt holders on identifying and preserving Russian-situated assets through Russian court proceedings, parallel insolvency engagement, and cross-border coordination with counsel in other jurisdictions. With over 1,000 matters handled since inception, the team provides direct partner involvement on every engagement and has particular experience in matters before the Siberian and Ural federal circuit courts.

For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction.

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/

The Federal Bailiff Service of the Russian Federation – the FSSP, the state authority responsible for executing civil judgments and enforcing creditor claims against debtors – issued operational guidance in April 2026 setting out its position on how enforcement requests from creditors operating within an OFAC-licensed framework should be processed. The guidance marks a meaningful shift in the administrative posture of Russian enforcement bodies towards foreign creditors whose recovery activities are subject to dual regulatory constraints: on one side, the procedural requirements of Russian civil enforcement law; on the other, the licensing and reporting obligations imposed by the United States Department of the Treasury's Office of Foreign Assets Control. For foreign creditors holding Russian-sited distressed assets or pursuing enforcement against Russian-domiciled debtors, the guidance creates both new procedural friction and – if navigated correctly – a clearer operational pathway than has previously existed.

Before this guidance, the FSSP applied a uniform procedural framework to all enforcement requests without any formal mechanism for acknowledging the OFAC-related constraints that many foreign creditors operate under. A foreign creditor holding a Russian court judgment or a recognised arbitral award could initiate enforcement proceedings in the ordinary way – submitting a writ of execution to the relevant bailiff's office, specifying the debtor's identified assets, and awaiting the bailiff's enforcement actions. The OFAC dimension was, in practice, invisible to the FSSP: the Service had no formal basis on which to acknowledge that a creditor's ability to receive funds, direct asset disposal, or engage with designated intermediaries might be constrained by US sanctions licensing requirements.

The April 2026 guidance changes this in three material respects. First, the FSSP has articulated a documentary protocol under which creditors who are subject to OFAC licensing conditions may submit a supplementary notification to the bailiff at the point of filing, identifying the specific licensing parameters that govern the transaction. This notification does not, in itself, suspend or modify the enforcement timeline – Russian enforcement law remains the lex operandi – but it creates an administrative record that is treated as relevant context if disputes arise over the timing or sequencing of asset transfers. Second, the guidance addresses the scenario in which the enforcement of a judgment would require funds to pass through a financial intermediary that is itself subject to OFAC-related restrictions; in those circumstances, the Service has indicated that bailiffs may, on application, defer the transfer step pending written confirmation from the creditor that the relevant licence conditions have been satisfied or that a specific licence has been obtained. Third, the FSSP has acknowledged, for the first time in a published guidance document, that the concept of "offshore asset Russia" – that is, Russian-registered assets ultimately beneficially owned through offshore structures – may require sequential enforcement steps across jurisdictions, and that the Service will, in appropriate cases, coordinate with Russian court authorities where multi-jurisdictional enforcement is documented in the case file.

Taken together, these three adjustments represent a Russia regulatory update of practical significance. They do not alter the substantive rights of creditors under Russian civil enforcement legislation; they do, however, create a more structured administrative environment for foreign creditors operating within OFAC-licensed parameters. The prior position, in which the FSSP treated every enforcement matter as a purely domestic procedural exercise, generated systemic friction for creditors whose transaction documents and fund flows needed to satisfy a parallel compliance architecture. The guidance reduces that friction at the administrative level, though it does not eliminate the underlying tension between Russian enforcement law and the extraterritorial reach of US sanctions regulation.

"The FSSP guidance does not resolve the substantive conflict between Russian enforcement law and OFAC licensing obligations – but it creates, for the first time, an administrative channel through which that conflict can be surfaced and managed procedurally." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign creditors holding enforcement claims against Russian debtors in a dual-regulatory environment, the procedural window created by this guidance is time-sensitive. If your recovery strategy has not been reviewed in light of this development, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The guidance is most immediately relevant to three categories of foreign creditor. The first is the trade creditor with an unsecured or judgment debt against a Russian debtor, where the creditor entity itself is a US person or is subject to OFAC jurisdiction by virtue of its ownership structure or the currency denomination of the original transaction. These creditors have historically faced a practical impasse: Russian enforcement machinery does not wait for foreign compliance processes to complete, but moving enforcement forward without satisfying OFAC requirements exposes the creditor to regulatory risk in its home jurisdiction. The FSSP's notification mechanism creates a formal record that enforcement was proceeding within a documented compliance framework – a meaningful protection when the creditor is reporting to US counsel or auditors on the status of its Russian enforcement activity.

The second category is the institutional or distressed investor that has acquired Russian-domiciled debt at a discount and is pursuing enforcement as part of a broader portfolio recovery strategy. For this category, the guidance's treatment of multi-jurisdictional enforcement is the most significant element. Where the ultimate beneficial ownership of a Russian asset sits in a Cypriot, Dutch, or BVI holding structure, the sequential enforcement steps across jurisdictions have historically been poorly coordinated at the Russian end. The FSSP's stated willingness to coordinate with court authorities where multi-jurisdictional documentation is on the case file is a procedural concession that distressed investors should document carefully in every new enforcement filing from this point forward.

The third category is the foreign creditor enforcing a pledge or security interest over a specific Russian asset – real property, equipment, or receivables – where the realisation of that security requires an asset to be valued, marketed, and sold through Russian enforcement procedures. Here, the guidance's deferral mechanism for fund transfers is directly relevant: creditors in this category should review whether the identification of the asset disposal intermediary – typically a specialist organisation approved by the FSSP – triggers any OFAC screening obligation, and, if so, whether a specific licence application or a general licence reliance determination needs to be placed on record before the FSSP bailiff proceeds to the disposal stage. Under Russian insolvency legislation and the civil enforcement framework, the bailiff's discretion to defer a transfer step is narrow; the guidance provides a rare procedural basis for a deferral that does not require the creditor to abandon the enforcement timeline entirely.

The guidance is less directly relevant to creditors whose enforcement activities are not subject to OFAC jurisdiction – for example, European creditors with no US nexus and whose debtor is not a designated person. Those creditors continue to operate under the standard Russian enforcement framework without the overlay of the FSSP's new protocol. However, they should be aware that the introduction of this administrative channel may affect the sequencing and prioritisation of enforcement actions in bailiff offices that are simultaneously processing OFAC-notified and non-notified files.

The guidance creates a defined window of opportunity for creditors who act promptly. Three steps warrant immediate attention.

The first is a structured review of the OFAC nexus in existing enforcement files. Any creditor that has an active enforcement writ lodged with a Russian bailiff's office, or that is planning to lodge one within the next quarter, should confirm whether its enforcement activities are subject to OFAC jurisdiction. This is not a question that can be answered by reference to the creditor's own nationality alone: the currency of the original debt, the involvement of US financial institutions in the transaction chain, and the ownership structure of both the creditor and the debtor entity are all relevant factors. Where an OFAC nexus is confirmed, the supplementary notification mechanism should be activated without delay.

The second step is a review of the asset realisation pathway for any security-backed enforcement. Where a specific asset has been identified for disposal under Russian enforcement procedures, the identity of the FSSP-approved disposal intermediary should be screened against OFAC consolidated lists, and the fund flow from disposal proceeds back to the creditor should be mapped against the applicable licence conditions. Creditors who have not conducted this mapping before the bailiff reaches the asset disposal stage may find that the deferral mechanism in the guidance is their only procedural recourse – and that its availability is not guaranteed.

The third step is the most broadly applicable: a review of the engagement between Russian enforcement counsel and the creditor's OFAC compliance team or external US counsel. For foreign creditor Russia enforcement matters with a dual-regulatory dimension, the FSSP guidance creates administrative documentation that will be relevant to both sets of advisers. Russian enforcement strategy and OFAC compliance strategy have historically been managed in separate silos; the guidance makes that separation operationally untenable for creditors who intend to use the new notification and deferral mechanisms.

Creditors who delay this review risk losing the procedural protections the guidance creates. Under Russian enforcement practice, the bailiff's timeline does not pause to accommodate creditor-side compliance processes unless a formal application has been made and accepted. The window between the guidance taking effect and the point at which active enforcement files will have progressed past the deferral-eligible stage is narrow; for creditors with live Russian enforcement proceedings, that window should be treated as a priority matter.

The firm acts for foreign creditors in Russian enforcement and asset recovery proceedings. To discuss how this guidance affects your recovery strategy, contact info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• OFAC Sanctions Intersection with Russian Asset Recovery: Practice Briefing
• Deep Dive: OFAC Sanctions Intersection with Russian Asset Recovery Strategy
• Asset Tracing and Recovery in Russia: Practice Overview

Q: What specifically changed with the Federal Bailiff Service's April 2026 guidance on OFAC-regulated enforcement?

A: The guidance introduced three procedural adjustments. First, the FSSP created a documentary notification mechanism allowing OFAC-regulated creditors to place their licensing constraints on the administrative record at the point of filing an enforcement writ. Second, it provided a deferral mechanism for fund transfer steps where an OFAC-related obstacle exists, contingent on a formal creditor application to the bailiff. Third, the FSSP acknowledged multi-jurisdictional enforcement scenarios – where Russian assets are beneficially owned through offshore structures – as a recognised category requiring cross-authority coordination. None of these changes alter substantive creditor rights under Russian civil enforcement law; they create an administrative framework for managing the procedural intersection between Russian enforcement procedure and extraterritorial US regulatory requirements.

Q: Which categories of foreign creditor are most directly affected by this Russian law change?

A: Three categories bear the most direct exposure. US-nexus trade creditors holding Russian judgment debts or recognised arbitral awards, where OFAC jurisdiction arises from the creditor's ownership structure or the currency of the original transaction, will need to activate the notification mechanism for every active and planned enforcement file. Distressed investors pursuing multi-jurisdictional recovery against Russian-domiciled debtors will find the FSSP's new coordination undertaking directly relevant to sequencing their enforcement steps. Security creditors enforcing pledges over specific Russian assets face the most granular compliance decision point: the identification and OFAC screening of asset disposal intermediaries must occur before, not after, the bailiff reaches the disposal stage.

Q: What is the most urgent action for a foreign creditor with live Russian enforcement proceedings?

A: The immediate priority is to determine whether the enforcement activity is subject to OFAC jurisdiction, and, if so, to lodge the supplementary notification with the bailiff before the file advances to the asset transfer or disposal stage. Under the guidance, the deferral mechanism is only available if a formal application has been made before the relevant enforcement step is taken. Creditors who have not yet mapped the OFAC dimension of their Russian enforcement proceedings should treat this as an urgent compliance and strategic matter. The firm can assist with both the Russian enforcement procedural steps and the coordination with OFAC-focused counsel in the relevant jurisdiction.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 – Russia's principal legal directory – for eight consecutive years.

The firm's asset tracing and recovery practice advises foreign creditors, institutional investors, and trade creditors on enforcement proceedings, judgment recognition, and cross-border asset recovery involving Russian-sited assets. The team works directly with foreign counsel on dual-jurisdiction matters, providing Russian procedural execution alongside the cross-border coordination that complex recovery mandates require. With over 1,000 matters handled since inception, the firm brings both procedural depth and direct partner involvement to 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/

Following clarifications issued by Russia's Supreme Court on the procedural treatment of digital assets and cryptocurrency in enforcement proceedings, foreign creditors pursuing Russian-domiciled debtors now face a materially altered landscape. The clarifications address a question that had, until recently, produced inconsistent outcomes across Russian arbitrazh courts: whether digital assets held by a debtor can be identified, frozen, and applied towards satisfaction of a judgment or insolvency claim. For foreign creditors holding Russian-law or foreign judgments against Russian counterparties, the practical implications extend well beyond the digital sector — any debtor with cryptocurrency exposure is now within the analytical scope of a creditor's asset search.

Before the Supreme Court's intervention, the enforcement of claims against digital assets in Russia occupied an uncertain procedural space. Digital assets — including cryptocurrency and digital financial assets — were acknowledged as property under Russian civil legislation, but the procedural mechanisms for tracing, freezing, and realising them had not been authoritatively consolidated. Enforcement practice varied by circuit. Some courts accepted creditor applications to freeze digital wallets; others declined on the basis that the enforcement officer lacked the statutory authority to compel custodians or exchanges. The result was a significant recovery gap: a debtor could hold material value in cryptocurrency while formal enforcement proceedings produced nothing.

The Supreme Court's clarification resolves the core procedural ambiguity. Under the prevailing interpretation, digital assets held by a natural person or legal entity are subject to the standard enforcement regime applicable to other property rights. Enforcement officers are now generally regarded as competent to apply to courts for orders requiring the identification and disclosure of digital asset holdings. Where a debtor holds cryptocurrency through a Russian-domiciled exchange or custody arrangement, that exchange or custodian may be obligated to respond to a court-ordered disclosure. The clarification also addresses the treatment of digital assets in insolvency proceedings: in the prevailing approach, creditors in a bankruptcy estate may now request that the administrator investigate digital asset holdings as part of the debtor's asset inventory — a step that was previously contested.

The shift is significant but should not be overstated. Enforcement against cryptocurrency held in self-custody wallets — where no exchange or custodian is involved — remains procedurally complex. The Supreme Court's guidance does not eliminate the technical challenge of wallet identification; it establishes the legal framework within which that challenge must be addressed. Courts in practice still require creditors to provide sufficient identifying information about the asset before a freeze order will issue.

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" "The Supreme Court's clarification establishes digital assets as fully within the enforcement perimeter of Russian law — a development creditors should integrate into their asset-search strategy before commencing enforcement proceedings." — Elizaveta Razina, Senior Lawyer, Practice Lead – Asset Tracing & Recovery, Vetrov & Partners

The clarification is most directly relevant to two categories of foreign creditor.

The first category is trade creditors and institutional lenders holding unsatisfied judgments or arbitral awards against Russian counterparties. Until recently, a debtor's cryptocurrency holdings were, in practical terms, invisible to standard enforcement. Following the Supreme Court's clarification, creditors instructing Russian enforcement counsel should now specifically direct asset searches to include digital asset inquiries — to Russian-registered exchanges and, where relevant, to insolvency administrators conducting debtor estate inventories.

The second category is foreign creditors participating in Russian insolvency proceedings. Insolvency administrators are now generally expected to investigate digital asset holdings as part of the standard debtor estate inventory. Creditors who fail to prompt this investigation — or who do not monitor whether the administrator has conducted it — risk allowing those assets to be overlooked or, in the most concerning scenarios, dissipated before the estate is fully mapped. Foreign trade creditors who have typically relied on the administrator to locate assets without creditor direction should reconsider that posture.

The clarification also has implications for foreign companies involved in corporate disputes where a counterparty has taken steps to move value into digital assets — a pattern that has appeared in distressed asset contexts involving Russian counterparties. For in-house counsel monitoring a Russian subsidiary or a joint venture partner showing signs of financial difficulty, the Supreme Court's guidance means that digital asset movement is now a legally cognisable indicator of potential asset dissipation, which may support an application for interim relief.

If you are a foreign creditor pursuing enforcement against a Russian debtor or participating in Russian insolvency proceedings, make an enquiry about digital asset tracing: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The primary practical consequence of the Supreme Court's clarification is that digital asset tracing must become a standard element of any pre-enforcement asset search in Russia — not an optional add-on reserved for technology-sector debtors.

For creditors with existing enforcement proceedings already under way, counsel should review whether asset investigation steps have included digital asset enquiries. If they have not, there may be scope to expand the investigation scope through a supplementary application to the relevant court or enforcement officer. The window for doing so matters: creditors who delay initiating or expanding enforcement proceedings face the risk that assets are moved or dissipated in the interim.

For creditors preparing to initiate enforcement proceedings against a Russian debtor, the asset search brief to Russian counsel should now explicitly include: identification of Russian-registered exchange accounts, digital financial asset accounts held through Russian-regulated custodians, and any digital asset interests disclosed in the debtor's corporate filings or related proceedings.

For creditors in insolvency proceedings, the recommended step is a formal written request to the insolvency administrator requiring confirmation that digital asset holdings have been investigated as part of the debtor estate inventory. If the administrator's response is inadequate, creditors are entitled in most circumstances to challenge the sufficiency of the estate inventory before the supervising court.

One structural limitation should be acknowledged. The Supreme Court's clarification operates within the framework of Russian domestic enforcement and insolvency law. Cross-border enforcement — for example, seeking recognition of a Russian court order requiring a foreign exchange to disclose a debtor's holdings — remains governed by the law of the relevant foreign jurisdiction and involves separate procedural steps. For cross-border digital asset tracing matters, we collaborate with trusted counsel in the relevant jurisdiction.

The clarification also leaves open certain questions about the valuation and liquidation of digital assets once identified. Russian enforcement and insolvency practice in this area continues to develop, and the procedural mechanics of converting cryptocurrency to fiat value within an enforcement estate remain subject to court-level evolution.

For a structured assessment of how this development affects your existing enforcement position or insolvency claim in Russia, request our practice review: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Navigating digital asset and cryptocurrency tracing in Russia: a practitioner guide
• Comparative analysis: digital asset and cryptocurrency tracing under Russian and foreign law
• Asset Tracing & Recovery in Russia: practice overview

Q: What specifically did the Supreme Court clarify about digital assets in Russian enforcement proceedings? A: The Supreme Court clarified that digital assets — including cryptocurrency and digital financial assets — are property subject to the standard Russian enforcement regime. Enforcement officers are now generally regarded as competent to apply for court orders requiring disclosure of a debtor's digital asset holdings. In insolvency proceedings, administrators are expected to investigate digital assets as part of the debtor estate inventory. The core change is procedural: it establishes clear authority for enforcement and insolvency mechanisms to reach digital assets, resolving inconsistency that had previously existed across Russian arbitrazh courts.

Q: Which foreign creditors are most directly affected by this development? A: Two groups face the most immediate practical relevance. First, trade creditors and institutional lenders holding unsatisfied judgments or awards against Russian counterparties — they should ensure their asset search briefs explicitly include digital asset inquiries to Russian-registered exchanges and custodians. Second, foreign creditors participating in Russian insolvency proceedings — they should monitor whether the insolvency administrator has investigated digital asset holdings, and should submit a formal written request if that step has not been confirmed. Creditors in either category who have not yet updated their recovery strategy in light of this development are at risk of overlooking assets that are now, in principle, reachable.

Q: What practical steps should a foreign creditor take in response to this clarification? A: Three steps are advisable. First, review any existing enforcement or insolvency proceedings to determine whether digital asset investigation has been conducted — and instruct counsel to expand the asset search if it has not. Second, for new enforcement proceedings, ensure the asset search brief to Russian counsel explicitly covers Russian-registered digital asset accounts and exchange relationships. Third, in insolvency proceedings, submit a written request to the administrator confirming that digital asset holdings form part of the estate inventory. For matters with a cross-border digital asset dimension — involving foreign exchanges or custodians — separate steps under the law of the relevant jurisdiction will be required, and we recommend taking specialist advice promptly.

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 and recovery practice advises foreign creditors, distressed investors, and corporate claimants on identifying and enforcing against assets held by Russian-domiciled debtors — including in insolvency proceedings, civil enforcement, and cross-border recovery matters. With over 1,000 matters handled since inception, the team brings direct partner involvement and circuit-level procedural knowledge to every engagement.

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

Make an enquiry about digital asset tracing or enforcement against a Russian debtor: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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 – Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

Amendments to Russia's beneficial ownership disclosure framework, which took effect in the latter part of 2026, have materially altered the obligations imposed on Russian legal entities — including those with foreign shareholders, beneficial owners, or creditors holding security over Russian assets. Under the amended legislation, the thresholds, reporting channels, and verification obligations have all been revised in ways that carry direct consequences for foreign creditors seeking to trace, preserve, or enforce against Russian-held assets. For distressed investors and trade creditors already engaged in enforcement proceedings in Russia, the regulatory change arrives at a moment when accurate beneficial ownership information is frequently the difference between a successful asset trace and a dead end.

Before the amendments took effect, Russian legal entities were required to identify and disclose their beneficial owners — defined as individuals exercising ultimate effective control — to their banks and, in prescribed circumstances, to the regulatory authorities. The disclosure obligation applied to entities subject to Russian anti-money-laundering legislation, with the threshold for beneficial ownership set at direct or indirect ownership of a qualifying percentage of share capital or equivalent voting rights.

The amended framework introduces several changes that are practically significant for foreign parties. First, the verification standard has been raised: entities are now required not merely to identify and record beneficial ownership information internally, but to take active steps to confirm the accuracy of that information through documentary evidence. Passive self-declaration by the purported beneficial owner is no longer sufficient in the majority of cases. Second, the scope of entities subject to enhanced disclosure obligations has been broadened to capture a wider range of holding structures, including those where indirect control is exercised through non-Russian intermediary layers. Third, the frequency of mandatory disclosure updates has been shortened, meaning that changes in beneficial ownership must be reported to the relevant authorities within a tighter timeframe than was previously required.

For foreign parties — whether creditors, shareholders, or counterparties assessing the ownership structure of a Russian debtor — the practical effect is twofold. Entities that comply with the amended framework will, in principle, generate more reliable and more current ownership records. However, entities that do not comply, or that have restructured their ownership in anticipation of the new rules, may present a different challenge: gaps or inconsistencies in the official record that complicate asset tracing.

"The amendments effectively raise the cost of opacity for Russian entities with complex foreign-linked ownership structures — but they also shift the burden of verification onto creditors who cannot assume that the official register reflects economic reality." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

If you are a foreign creditor seeking to understand how the amended disclosure framework affects your enforcement position in Russia — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The amendments are most immediately relevant to three categories of foreign creditor operating in the Russian market.

Trade creditors holding unsecured claims against Russian counterparties are affected because beneficial ownership information is a primary tool for identifying assets available for enforcement. Where a Russian debtor has undergone ownership restructuring — whether in anticipation of insolvency or in response to other commercial pressures — the amended disclosure obligations create a formal record of the pre-restructuring ownership position. This record may be used by creditors in avoidance proceedings or in tracing claims where assets have been transferred to related parties.

Secured creditors holding pledges or mortgages over Russian assets are affected in a different way. The amended framework requires that the entity granting security maintain an accurate beneficial ownership record. Where discrepancies emerge between the registered owner of pledged assets and the entity identified as beneficial owner in disclosure filings, questions of enforcement priority and title may arise. Foreign creditors who took security before the amendments took effect should review the current compliance position of their Russian counterparty and consider whether updated representations and warranties are warranted.

Distressed investors who have acquired or are considering acquiring Russian debt instruments at a discount face particular exposure. Under Russian insolvency legislation, preferential transfer claims may be brought for transactions completed within a defined period before the bankruptcy filing — and a beneficial ownership disclosure record that reveals a change of control in that window may be used against a distressed purchaser who did not conduct adequate pre-acquisition due diligence. This is a risk that investors familiar with US or English restructuring markets frequently underestimate when entering Russian distressed positions.

The amended framework also affects foreign shareholders who hold minority stakes in Russian operating entities. Where a foreign shareholder falls within the beneficial ownership threshold under the revised rules, the entity has an obligation to disclose that shareholder's details to the relevant authorities. Failure by the Russian entity to comply does not relieve the foreign shareholder of reputational and relationship risk — and, in enforcement scenarios, a missing or inaccurate disclosure record may complicate the shareholder's ability to demonstrate that its stake is unencumbered.

For distressed investors assessing a Russian position, early-stage beneficial ownership analysis can determine whether enforcement is viable before significant costs are committed. Speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The amended disclosure framework creates both risks and opportunities for foreign creditors. The risks — described above — are primarily those of encountering a non-compliant or restructured counterparty. The opportunities arise from the fact that a compliant Russian entity will now maintain a more comprehensive and more current beneficial ownership record, which may be accessed through the formal regulatory and judicial channels available to creditors in enforcement proceedings.

For creditors currently engaged in Russian enforcement proceedings, the priority is to assess whether the entity against which they are enforcing has filed the required updated disclosures under the amended framework. Where disclosures have not been updated as required, this is itself a regulatory breach — one that the relevant authorities may act upon independently, and one that creditors may draw to the attention of the court or insolvency administrator as evidence of the debtor's conduct.

For creditors in the pre-litigation or early investigation stage, the amended framework strengthens the case for commissioning a formal beneficial ownership trace through Russian regulatory channels before committing to an enforcement strategy. The Asset Tracing & Recovery practice at Vetrov & Partners regularly assists foreign creditors in obtaining beneficial ownership information through the available regulatory, notarial, and court-ordered disclosure mechanisms in Russia.

For foreign creditors who hold security and are not yet in default, the practical step is to obtain updated representations from the Russian counterparty confirming its compliance with the amended disclosure obligations — and to consider whether a covenant requiring ongoing compliance should be built into any refinancing or amendment agreement.

For creditors assessing a potential distressed acquisition of Russian debt, pre-acquisition beneficial ownership due diligence should now include a review of the target entity's disclosure filings for the period covered by the amendment, with particular attention to any changes in the registered beneficial owner during that period.

Further background on the underlying disclosure obligations — as they stood before the amendment — is set out in our earlier analysis Beneficial Ownership Disclosure Obligations under Russian Law. Practical considerations for creditors assessing enforcement strategy in light of ownership complexity are addressed in Strategic Considerations in Beneficial Ownership Enforcement.

The amended framework, like most Russian legislative changes of this scope, leaves a number of implementation questions to be resolved through regulatory guidance and, ultimately, court practice. At the time of writing, the following points remain subject to interpretation.

The treatment of beneficial owners who are foreign nationals resident outside Russia is not fully addressed in the primary legislation. The amended verification standard requires documentary confirmation, but the types of document that will satisfy the regulator's expectations for foreign individuals — where Russian-standard documentation may not be available — is a matter on which formal guidance has not yet been issued. Creditors relying on beneficial ownership records involving foreign nationals should treat those records with appropriate caution until the verification standard is clarified.

The interaction between the amended disclosure obligations and Russia's asset freeze and restriction measures — which apply to certain categories of foreign-held assets — is also an area of uncertainty. Where a Russian entity's beneficial owner is a foreign national or foreign entity subject to restrictions, it is not yet established whether the disclosure obligation operates independently of, or is affected by, those restrictions. This is a point on which legal advice specific to the client's position is essential before drawing conclusions.

Q: What specifically changed in Russia's beneficial ownership disclosure rules under the amended legislation?

A: The amended legislation raises the verification standard for beneficial ownership disclosures: entities can no longer rely solely on self-declaration by the purported owner and must obtain documentary confirmation of accuracy. The scope of entities subject to enhanced obligations has been broadened to capture more complex holding structures, including those with non-Russian intermediary layers. The frequency of mandatory updates has been shortened, so changes in beneficial ownership must be reported to the relevant authorities within a tighter timeframe than before. The practical effect is that compliant entities will hold more current and more verifiable ownership records — which is directly relevant to creditors conducting asset traces.

Q: Which types of foreign creditor are most directly affected by the changes, and how?

A: Three groups face the most direct impact. Unsecured trade creditors benefit from improved ownership records where the counterparty is compliant, but face greater complexity where restructuring has occurred ahead of the amendment. Secured creditors should review whether discrepancies between registered asset ownership and disclosed beneficial ownership affect their enforcement priority. Distressed investors acquiring Russian debt positions face the most acute due diligence obligation: beneficial ownership disclosure filings for the period covered by the amendment are a material input in assessing insolvency-related transaction risk. Foreign minority shareholders in Russian entities should also confirm that the Russian entity has updated its filings to reflect their current stake, to avoid complications in any future enforcement or sale process.

Q: What should a foreign creditor do first in light of these changes?

A: The starting point is to establish whether the Russian entity concerned — debtor, counterparty, or target of a distressed acquisition — has filed the updated beneficial ownership disclosures required under the amended framework. If it has not, that non-compliance is itself an actionable point in enforcement proceedings and may be raised before the relevant regulatory authorities. If it has complied, the updated filings are a primary source of information for asset tracing and enforcement strategy. For creditors who are not yet in proceedings, commissioning a formal beneficial ownership trace through Russian regulatory and judicial channels — before committing to an enforcement strategy — is the appropriate next step.

• Beneficial Ownership Disclosure Obligations under Russian Law
• Strategic Considerations in Beneficial Ownership Enforcement
• Asset Tracing and Recovery in Russia: A Creditor's Guide

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 trade creditors, institutional investors, and distressed debt purchasers on identifying, preserving, and enforcing against Russian-held assets. Engagements regularly involve regulatory disclosure channels, court-ordered asset disclosure, and cross-border coordination with counsel in creditor-home jurisdictions. With over 1,000 matters handled since inception, the team combines procedural depth with direct partner involvement on every engagement.

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

If the amended beneficial ownership disclosure rules affect your enforcement position or your assessment of a Russian distressed position — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

Foreign creditors pursuing enforcement against Russian debtors have long encountered nominee arrangements as a structural barrier: assets held through interposed nominees — individuals or entities whose formal ownership conceals the debtor's beneficial interest — have frustrated recovery across asset classes from real estate to shareholdings. In the period since mid-2025, the Federal Bailiff Service (FSSP) has adopted a markedly more interventionist posture toward these structures, using expanded procedural tools to look behind formal title and reach assets that debtors ostensibly no longer own. For foreign creditors holding enforceable judgments or arbitral awards against Russian counterparties, this shift materially changes the asset-recovery calculus — and the window for deploying these tools in active enforcement is narrower than the headline change implies.

Until recently, FSSP enforcement practice in Russia was largely confined to a document-led approach: bailiffs would search official registries, identify assets registered in the debtor's name, and proceed against those assets. Where formal ownership had been transferred to a nominee — whether a family member, a related company, or an offshore vehicle — the standard enforcement process typically stalled at the boundary of registered title. Creditors wishing to reach through to beneficial assets had to initiate separate civil proceedings and satisfy courts that the transfer was either sham or voidable. That process was time-consuming and offered no guarantee of interim preservation.

The prevailing approach has shifted in two respects. First, the FSSP has been operating under revised internal guidance that treats nominee-title structures as a category warranting enhanced investigation, rather than a definitive boundary on enforcement scope. In practice, this means bailiffs are now more commonly requesting transactional documentation behind asset transfers, cross-referencing property and corporate registries with tax authority data, and flagging structures for supplementary investigation where the transfer occurred in proximity to the judgment debt. Second, courts across the principal commercial circuits have been more receptive to FSSP-initiated applications to suspend disposals pending full investigation of beneficial ownership — a form of interim measure that was rarely granted at the bailiff's request prior to this period.

The practical consequence for foreign creditors is significant. A debtor who transferred real estate, shares, or receivables to a nominee within the period commonly subject to challengeable-transfer review may find that the transfer is exposed to FSSP-led unwinding, rather than requiring a separate creditor application. However, creditors should not assume that FSSP intervention is automatic or uniform. Practice varies by regional enforcement department and by asset class; the strongest results observed to date have been in matters involving Russian real estate and registered shareholdings in Russian limited liability companies, where registry records allow documentary tracing. Offshore asset structures — where the nominee holds shares in a foreign company rather than domestic assets — remain materially harder to unwind through domestic enforcement, and typically require parallel proceedings in the nominee vehicle's jurisdiction.

Under the standard interpretation now applied by the majority of enforcement offices, the relevant review period for asset transfers runs to several years before the enforcement title was issued — a window that creditors who have held dormant judgments without pursuing active enforcement may find more constraining than anticipated.

For foreign creditors assessing whether enforcement in Russia against a nominee-structured debtor is viable, the procedural window is a live variable. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The shift in FSSP enforcement posture does not affect all creditors equally. The creditors most directly positioned to benefit are those holding a Russian enforcement title — a judgment of a Russian arbitrazh court, a Russian court order recognising a foreign arbitral award, or an enforceable writ issued through standard recognition proceedings — against a debtor whose assets have been placed into a domestic nominee arrangement within Russia. Creditors at the other end of the spectrum — holding foreign judgments not yet recognised in Russia, or chasing assets held entirely outside Russian jurisdiction — face a materially different and more limited picture.

Three creditor profiles draw particular attention under the current enforcement trend.

Trade creditors who obtained Russian arbitrazh court judgments against Russian counterparties are the most immediate beneficiaries. Where the counterparty debtor transferred operating assets — machinery, real estate, receivables — to an associated party after the commercial dispute arose, the FSSP is now more willing to treat such transfers as warranting challenge and to preserve the assets pending resolution. The speed with which this investigation is initiated after enforcement proceedings are opened has improved in practice, though it remains uneven across regions.

Foreign institutional creditors holding pledge or mortgage security over Russian assets occupy a distinct position. Their principal concern is whether a nominee arrangement created after the security was granted may be used to strip the asset from the security interest. The prevailing view in Russian courts is that a pledge properly registered before the nominee transfer was completed survives the transfer and can be enforced against the current holder — including a nominee who took with notice of the pledge. FSSP bailiffs have generally proceeded on this basis in recent matters, though creditors should verify the registration chain carefully before relying on this position.

Foreign creditors with only an unrecognised foreign judgment — including those issued by courts in EAEU or CIS member state jurisdictions — face a preliminary step: recognition in a Russian court is required before domestic enforcement tools, including the enhanced nominee-investigation approach, become available. Recognition under EAEU and bilateral treaty frameworks is a distinct procedural route with its own timelines, and should be initiated without delay where a debtor's Russian assets have been identified.

"The most consequential aspect of the current FSSP posture is not the formal legal change but the shift in investigative practice — bailiffs are now treating nominee structures as a starting point for inquiry, not a terminus." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement & Asset Tracing, Vetrov & Partners

If your enforcement matter involves a Russian debtor with suspected nominee-held assets, early engagement with local counsel determines what tools remain available. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The current enforcement environment in Russia rewards creditors who act on information early. Nominee arrangement risks for foreign creditors arise not only from the structure itself but from the gap between a creditor's knowledge of the arrangement and the moment at which FSSP investigation can be engaged. The following steps reflect the practical sequence that produces the most effective outcomes under the prevailing approach.

Establish whether an enforcement title is in place. FSSP investigation tools are only available once enforcement proceedings have been opened on the basis of a valid Russian enforcement title. Foreign creditors holding awards or judgments that have not been recognised in Russia should treat recognition as the immediate priority — the enhanced nominee-investigation procedure is inaccessible until that step is complete.

Map the debtor's asset position as comprehensively as possible before opening enforcement. Russian corporate and property registries permit pre-enforcement searches, and professional asset-tracing can often identify nominee-held real estate and shareholdings before the FSSP begins its own inquiry. This prior mapping allows counsel to direct the FSSP investigation toward specific assets and specific transactions, which materially improves the efficiency of the enforcement process.

Assess the timeline of nominee transfers against the challengeable-transfer period. The vulnerability of a nominee arrangement to unwinding depends significantly on when the transfer occurred relative to the debt and the enforcement title. Transfers completed long before the debt arose are generally less exposed; transfers completed after the debt was known to the debtor are the primary target of FSSP investigation. Legal analysis of the transfer timeline should be conducted before enforcement proceedings are opened, since the position can inform both the enforcement strategy and any applications for interim preservation.

Consider whether parallel proceedings are needed for offshore elements. Where nominee structures involve assets held outside Russia — shares in a foreign company, bank accounts in a foreign jurisdiction — domestic Russian enforcement tools will generally not reach those assets directly. Foreign creditors should assess whether the jurisdiction of the offshore nominee vehicle offers recognition of Russian enforcement titles or other procedural routes to asset preservation, and engage trusted counsel in that jurisdiction accordingly. Vetrov & Partners collaborates with trusted counsel in relevant foreign jurisdictions on cross-border enforcement matters of this type.

Finally, engage with the FSSP process actively, not passively. Creditors who assume that the FSSP will identify and unwind nominee structures without creditor input frequently find that enforcement stalls. The enhanced investigative posture of the FSSP benefits creditors who provide documentary foundations for the inquiry — transactional records, corporate registry chains, evidence of beneficial ownership. In practice, the most productive enforcement outcomes in nominee-structured matters have involved close coordination between creditor-side counsel and the assigned bailiff.

The current enforcement trend raises a number of interpretive questions that have not yet been fully resolved by judicial practice or formal regulatory clarification.

The scope of the FSSP's investigative authority over offshore nominee elements remains contested. The prevailing view is that the FSSP may request information about offshore nominee vehicles through existing international legal assistance mechanisms, but the practical utility of those mechanisms varies widely by jurisdiction, and response timelines frequently exceed the enforcement window.

Courts have not yet produced consistent guidance on what constitutes adequate evidence that a domestic nominee arrangement is sham rather than legitimate. In some circuits, creditors have succeeded in unwinding nominee transfers on a documentary basis alone — demonstrating financial flows inconsistent with arm's-length transfer terms. In others, courts have required more direct evidence of the debtor's retained beneficial control. This inconsistency means the strength of a nominee-challenge case may depend significantly on the circuit in which enforcement is pursued.

There is also an open question about the interaction between the enhanced FSSP investigative posture and parallel insolvency proceedings. Where a debtor has filed for or been declared insolvent, the insolvency administrator holds primary authority to challenge voidable transactions — including nominee transfers. The relationship between the FSSP's enforcement authority and the insolvency administrator's transaction-challenge rights is an area where creditors should seek specific advice rather than assume that the FSSP's enhanced posture will extend into insolvency-adjacent situations without procedural complication.

• How Russian courts approach nominee arrangements: a creditor's guide
• Anatomy of nominee arrangement risks and unwinding: what foreign creditors need to know
• Asset Tracing & Recovery practice overview

Q: What specifically changed in the Federal Bailiff Service's approach to nominee arrangements?

A: The FSSP shifted from a registry-led enforcement process — in which assets not registered in the debtor's name were largely out of reach — to an active investigative posture that treats nominee-held assets as a category warranting structured inquiry. In practice, bailiffs are now requesting documentation behind asset transfers, cross-referencing registries with tax data, and seeking court-granted interim measures to preserve nominee-held assets pending investigation. This change is reflected in enforcement office guidance and in judicial receptiveness to FSSP-initiated preservation applications. The change does not alter the statutory framework for challenging voidable transfers, but it means the FSSP is now a more active participant in the investigation process than previously.

Q: Which foreign creditors are directly affected by this development, and how?

A: The most directly affected creditors are those who already hold a Russian enforcement title — a Russian arbitrazh court judgment or a recognised foreign arbitral award — against a debtor with Russian assets held through nominee arrangements. These creditors can now engage the FSSP's enhanced investigative tools immediately upon opening enforcement proceedings. Foreign creditors holding unrecognised foreign judgments, including judgments from EAEU or CIS member states, must complete recognition proceedings first. Creditors chasing purely offshore nominee structures face a further limitation: the FSSP's enhanced posture applies primarily to domestic Russian assets; offshore elements typically require parallel proceedings in the relevant foreign jurisdiction.

Q: What should a foreign creditor do immediately if it suspects its Russian debtor is using a nominee structure to conceal assets?

A: The priority actions are: first, confirm whether a Russian enforcement title is in place — if not, initiate recognition proceedings without delay. Second, conduct a documentary asset-mapping exercise using Russian registry searches to identify nominee-held real estate and shareholdings before FSSP investigation begins. Third, obtain legal analysis of the timeline of any nominee transfers relative to the debt, to assess which transfers are within the challengeable-transfer window. Fourth, assess whether offshore elements require parallel proceedings in a foreign jurisdiction. Active engagement with Russian enforcement counsel at the earliest opportunity — before assets are further dissipated — is the single most consequential step a creditor in this position can take.

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 and recovery practice advises foreign creditors — including trade creditors, institutional investors, and pledge holders — on enforcement against Russian debtors, including matters involving nominee arrangements, offshore asset structures, and cross-border recovery across EAEU and CIS jurisdictions. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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 & Asset Tracing, Vetrov & Partners vetrovpartners.com/razina/

Following amendments to the Russian civil law framework that came into force in early 2027, the analytical criteria applied by Russian courts to fraudulent transfer claims have shifted in ways that directly affect foreign creditors seeking to trace assets and pursue recovery in Russia. The changes refine what courts treat as probative conduct when assessing whether a pre-insolvency transaction was designed to place assets beyond a creditor's reach, and they alter the evidentiary weight attributed to the debtor's knowledge of insolvency at the point of transfer. For foreign creditors holding claims against Russian counterparties — and for distressed investors acquiring those claims — the updated framework creates both new grounds for challenge and new procedural traps that must be identified early in the recovery process.

Before the 2027 amendments, Russian courts assessed fraudulent transfers under a largely fact-specific standard drawn from the general provisions of Russian civil legislation and supplemented by the Russian Supreme Court's guidance on voidable transactions. The principal question was whether the debtor, at the time of the transaction, was aware of its own insolvency or the imminence of it, and whether the transferee received the asset for less than market value or with knowledge of that insolvency. Courts had considerable latitude in weighing these factors, and practice varied materially between first-instance courts in different circuits.

The 2027 amendments introduced a more structured analytical framework. Russian civil law now establishes a graduated presumption system for fraudulent transfer analysis: where a transaction occurred within a specified look-back period before insolvency proceedings were initiated, and where the transferee is a person connected to the debtor — including affiliated companies, directors, and certain family members — courts are now directed to apply a rebuttable presumption that the transfer was made with intent to defraud creditors. The burden of disproving that presumption falls on the transferee.

Separately, the amendments expand the definition of "connected persons" for the purposes of fraudulent transfer analysis under Russian civil law. Categories that were previously assessed on a case-by-case basis — including indirect shareholding structures and certain contractual counterparties with historical dealings with the debtor — now fall within a codified definition. This has practical significance: it means that a foreign creditor tracing assets transferred to what appeared to be an unrelated third party may now be able to invoke the presumption if the structural connection can be demonstrated through corporate documentation.

The before-and-after distinction is, in short, this: previously, a creditor carried the primary evidentiary burden throughout a fraudulent transfer challenge in Russia. Under the amended framework, a creditor who can establish the look-back period, the connected-person relationship, and the timing of insolvency can shift that burden to the transferee.

The practical beneficiaries of the 2027 amendments are creditors holding claims against Russian entities that moved assets in the period leading up to formal insolvency. Foreign trade creditors, institutional investors holding distressed Russian debt, and foreign companies that supplied goods or services to a Russian counterparty that subsequently became insolvent are the categories most directly engaged by this regulatory update.

"The expanded connected-person definition is, in our experience, the change with the greatest immediate impact for foreign creditors — it removes what was previously a significant structural obstacle in cases where assets had been moved to subsidiaries or counterparties at arm's length in form but not in substance." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The extended definition of connected persons has particular relevance for creditors pursuing assets that were transferred within group structures. Where a Russian debtor transferred operating assets — real estate, receivables, intellectual property, plant and equipment — to a sister company, a subsidiary, or a company under common ultimate beneficial ownership, the new codified definition may encompass that transfer within the presumption. This does not make the challenge automatic: the creditor still needs to identify and document the connection, establish the timing, and file within the applicable limitation period.

The limitation period point is critical for foreign creditors who may not be monitoring Russian insolvency proceedings in real time. Under Russian insolvency legislation, the window for initiating a voidable transaction claim is calculated from the point at which the creditor knew or ought to have known of the grounds for challenge — not from the date of insolvency itself. Foreign creditors operating at a distance from the Russian market frequently underestimate how early that clock begins to run. A creditor that learns of a distressed Russian counterparty through market intelligence but does not promptly obtain local Russian legal advice on whether a fraudulent transfer challenge is available risks having the limitation period expire before a claim is filed.

For distressed assets Russian law positions in particular — that is, for investors who have acquired claims against Russian entities at a discount with a view to recovery — the 2027 amendments improve the structural case for fraudulent transfer litigation in Russia, but they do not eliminate the need for early-stage asset tracing. The presumption shifts the evidentiary burden once certain threshold facts are established; it does not substitute for establishing those facts in the first place.

For foreign creditors assessing the viability of a fraudulent transfer claim under the updated Russian framework, an early assessment of the connected-person relationship and look-back period is essential before limitation becomes a live risk — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical priority for foreign creditors following the 2027 amendments is a structured review of any outstanding or potential claims against Russian counterparties where asset transfers occurred in the three-year period before a formal insolvency filing — or, in cases where insolvency has not yet been declared, in the period during which signs of financial distress were visible.

That review should address three questions. First, does the transfer fall within the look-back period established by the amendments? The period is calibrated by reference to the commencement of insolvency proceedings, and understanding exactly when proceedings were or are likely to be initiated requires local knowledge of the specific proceeding. Second, can the transferee be brought within the expanded connected-person definition? This requires corporate structure analysis — ownership chains, officer overlaps, historical contractual relationships — which may need to be sourced from Russian commercial registry data and supplementary documentation. Third, is the limitation period for a voidable transaction challenge still open?

Where a foreign creditor has not yet filed in the Russian insolvency proceeding, the first step is to register a claim in the creditors' register — the foundation for any subsequent fraudulent transfer challenge under Russian insolvency legislation. A creditor that is not registered as a creditor in the insolvency proceeding typically lacks standing to bring a voidable transaction claim directly.

The jurisdictional architecture of Russian insolvency proceedings means that fraudulent transfer challenges are filed before the same arbitrazh court hearing the insolvency case. Foreign creditors unfamiliar with that court's specific procedural requirements — document authentication, translation standards, the mechanics of registered creditor participation — frequently encounter delays that compound the limitation risk. Asset tracing and recovery for foreign creditors in Russia requires simultaneous management of registration, limitation monitoring, and corporate investigation.

For creditors with pre-existing arbitral awards or court judgments against a Russian debtor, the amended fraudulent transfer framework is a complementary enforcement tool rather than a substitute for direct enforcement. If the debtor's identifiable assets in Russia have been moved, a fraudulent transfer challenge aimed at clawing back those assets for the insolvency estate — and thereby improving the creditor's recovery within the distribution waterfall — may represent the most viable path to value. This analysis is case-specific and depends on the position in the creditors' register, the nature of the transferred assets, and whether the transferee is itself solvent and present in Russia.

Creditors reviewing potential fraudulent transfer claims against Russian counterparties are encouraged to contact the team for an initial assessment of the available grounds, the limitation position, and the likely procedural pathway — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Foreign creditors and fraudulent transfer analysis in Russia
• Fraudulent transfer analysis under Russian civil law — a practitioner's guide
• Asset tracing and recovery for foreign creditors

Q: What specifically changed in the Russian fraudulent transfer framework in 2027?

A: Russian civil law amendments effective in 2027 introduced a graduated rebuttable presumption for transactions falling within a specified look-back period before insolvency, where the transferee is a connected person. Before the amendments, courts assessed each transaction under a broad fact-specific standard with the creditor bearing the primary evidentiary burden. The amendments shift that burden to the transferee once threshold conditions — look-back period, connected-person status, and insolvency timing — are established by the creditor. Separately, the definition of connected persons was codified and expanded to cover indirect shareholding structures and certain established contractual counterparties, categories that previously required case-by-case argument.

Q: Which foreign creditors are most affected by the 2027 amendments to Russian fraudulent transfer law?

A: The amendments are most directly relevant to foreign trade creditors, institutional distressed-debt investors, and foreign companies holding claims against Russian entities that became insolvent within the relevant look-back period. Creditors whose Russian counterparties transferred assets to group companies, subsidiaries, or structurally connected counterparties before insolvency will find the expanded connected-person definition particularly significant — it may bring previously difficult cases within the scope of the rebuttable presumption. Creditors who have not yet registered claims in Russian insolvency proceedings, or who have not obtained local Russian legal advice on limitation periods, face the greatest risk of being time-barred before the 2027 framework benefits them.

Q: What should a foreign creditor do immediately in light of the 2027 Russian fraudulent transfer amendments?

A: The immediate priority is a structured review of any outstanding claims against Russian counterparties where asset transfers occurred in the look-back period before insolvency. That review should assess: whether the transferee falls within the expanded connected-person definition; whether the limitation period for a voidable transaction challenge remains open; and whether the creditor is registered in the Russian insolvency proceeding — registration is typically a prerequisite for standing to challenge. Early engagement of Russian counsel with experience in both insolvency proceedings and asset tracing is essential, as the procedural steps — registration, corporate investigation, and challenge filing — must be managed simultaneously to avoid limitation risk.

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

The firm's asset tracing and recovery practice advises foreign creditors, distressed investors, and institutional claimants on the full procedural spectrum of Russian recovery mandates — from creditor registration in insolvency proceedings to fraudulent transfer challenges and cross-border enforcement. With over 1,000 matters handled since inception, the team combines direct partner involvement with deep procedural knowledge of the arbitrazh court system across the Siberian and Ural federal districts.

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/

Following a documented shift in arbitrazh court practice across several Russian federal districts in late 2025 and early 2026, the threshold for obtaining interim relief — including asset freezes — has become materially more demanding for applicants, including foreign creditors enforcing claims under Russian law. What had previously been treated by many courts as a largely procedural gateway has, in a number of circuits, evolved into a substantive examination of the applicant's evidentiary case. For foreign creditors and enforcement counsel operating on a live claim, understanding precisely what changed, who bears the practical burden, and what documentation is now required at the application stage is not a point of academic interest — it is a matter of whether interim measures are granted before assets are dissipated.

Russian procedural law on interim measures — governed by the arbitrazh procedural framework — has long set out two principal grounds on which a court may grant interim relief: the risk that non-grant will make enforcement of a future judgment impossible or substantially more difficult, and the need to prevent significant harm to the applicant. Neither ground is new. What has shifted is how courts in practice assess and weigh the evidence submitted in support of those grounds, and the degree to which they will examine the merits of the underlying claim at the interim stage.

In late 2025, a pattern emerged across several Siberian, Ural, and Volga circuit courts: applications supported only by the existence of a claim — without accompanying evidence of asset dissipation risk, unexplained counterparty conduct, or specific indicators of insolvency — were being declined at a significantly higher rate than in prior periods. Courts began requiring applicants to demonstrate, with documentary support, that the risk of dissipation was concrete and proximate, not merely theoretical. Formulaic recitations of the statutory grounds, which had previously been sufficient in a number of jurisdictions, were being treated as inadequate.

The shift also affected the proportionality assessment. Courts began examining whether the specific interim measure sought — a full asset freeze, a prohibition on disposals, or an injunction against specific transactions — was proportionate to the amount of the claim and the nature of the risk identified. Applications seeking broad freezing orders over assets whose value substantially exceeded the claimed sum drew heightened scrutiny and, in several instances, partial grants limited to assets whose value more closely corresponded to the claim value.

For foreign creditors pursuing enforcement of Russian-law claims — whether arising from supply agreements, loan facilities, pledge enforcement, or judgments being converted into Russian proceedings — this shift in court practice alters the preparation required before an interim relief application can be filed with a realistic prospect of success.

Foreign creditors preparing interim relief applications in Russian courts should seek specialist local counsel before the application is filed — not after a first refusal. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical impact falls most heavily on three categories of foreign creditor.

First, trade creditors holding Russian-law governed supply or distribution agreements, where the counterparty is a Russian legal entity and the underlying claim has not yet ripened into a judgment or arbitral award. In these situations, the creditor must typically demonstrate both the existence of a well-founded claim and a concrete risk of asset dissipation — a double evidentiary burden that the more demanding court practice has made considerably harder to satisfy without documentary evidence of counterparty behaviour suggesting imminent disposal or concealment.

Second, institutional creditors and distressed debt purchasers who have acquired claims against Russian entities — particularly where the original creditor relationship was established under a foreign-law agreement that is being enforced through Russian court proceedings. Courts in these matters have, in some instances, been attentive to the gap between the foreign-law transaction documents and the Russian-law evidentiary requirements for interim relief, and have expected applicants to bridge that gap explicitly in their application materials.

Third, creditors seeking to enforce foreign arbitral awards or foreign court judgments in Russia, where interim measures are sought during the recognition and enforcement proceedings. Under Russian law, interim relief is available during enforcement proceedings, but the applicant's ability to demonstrate the requisite risk of harm is constrained by the fact that the underlying merits have already been determined elsewhere — courts have shown some reluctance to treat the award itself as sufficient evidence of dissipation risk, and have required additional indicators specific to the Russian debtor's conduct.

For creditors who delay initiating enforcement proceedings in Russia, the risk is compounded: a debtor who becomes aware of an imminent claim may take asset-disposal steps within a window of weeks, and an interim relief application that fails on evidentiary grounds at first instance leaves the creditor without protection during the period required to cure the application and refile.

Three adjustments to enforcement strategy are indicated by this shift in Russian court practice.

First, pre-application due diligence on the debtor's Russian asset base should be completed before any interim relief application is filed. An application that identifies specific assets — registered real property, bank account holdings at named institutions, equity stakes in Russian subsidiaries — is materially better positioned than a general application for a freeze over all assets. Courts responding to detailed, asset-specific applications are more likely to grant the measure sought, and the proportionality review is easier to satisfy when the applicant has anchored the application to identified assets whose value corresponds to the claim.

Second, the evidential package accompanying the application should address dissipation risk directly, with documentary support where available. Indicators courts have treated as relevant include: evidence of unexplained asset transfers in the period preceding the claim, counterparty corporate restructuring or change of ownership, evidence of deteriorating financial position, and the commencement or threatened commencement of other creditor proceedings. None of these indicators is determinative in isolation, but a combination of two or more — documented and presented in the application — substantially strengthens the threshold showing.

Third, enforcement counsel instructed on cross-border matters involving Russian assets should review the applicable procedural timetable. Under Russian procedural rules, interim relief applications are typically considered within one business day, which creates a short window for court to examine materials. Well-prepared, clearly structured applications that present the legal grounds and supporting evidence concisely — without requiring the court to draw inferences from documents that speak to the merits rather than the interim risk — are better suited to the procedural timetable than comprehensive submissions designed for a merits hearing.

For more on the applicable legal framework and the statutory criteria governing interim measures in Russia, see The law and practice of interim relief applications in Russian courts. A detailed risk analysis for applicants is set out in Key risk points in interim relief applications in Russian courts.

The firm's Asset Tracing & Recovery practice advises foreign creditors at all stages of enforcement in Russia, including pre-application asset identification, interim relief applications before arbitrazh courts, and coordination with foreign counsel on cross-border enforcement matters.

• The law and practice of interim relief applications in Russian courts
• Key risk points in interim relief applications in Russian courts
• Asset Tracing & Recovery practice: Vetrov & Partners

Q: What specifically changed in how Russian arbitrazh courts assess interim relief applications in 2026?

A: The principal change is evidentiary: courts in several federal circuits moved from treating the existence of a claim as near-sufficient to satisfy the dissipation-risk ground, to requiring concrete documentary evidence that dissipation is a real and proximate risk. Applications relying on formulaic statutory recitations without supporting evidence of debtor conduct are being declined at a higher rate. Courts also began applying a more active proportionality review, with freezing orders limited more closely to the value of the claim where the applicant sought broader measures.

Q: Which types of foreign creditor are most directly affected by this court practice development?

A: The shift is most consequential for three groups: trade creditors pursuing Russian-law claims against Russian counterparties before a judgment has been obtained; institutional creditors and distressed debt purchasers enforcing claims acquired under foreign-law instruments through Russian proceedings; and creditors seeking interim relief during recognition and enforcement of foreign arbitral awards or judgments in Russia. In each case, the application package must now demonstrate — with supporting documents — a concrete risk specific to the Russian debtor, rather than relying on general assertions of enforcement difficulty.

Q: What is the recommended practical step for a foreign creditor considering an interim relief application in Russia now?

A: The most important step is to instruct specialist Russian counsel before preparing the application, not after a first refusal. Pre-application work should cover: identifying and documenting the specific Russian assets to be frozen, assembling evidence of debtor conduct that indicates dissipation risk, and calibrating the measure sought to the value and nature of those identified assets. An application built on this basis is substantially better positioned under the current court practice than one filed on urgency grounds without prior preparation.

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

The firm's Asset Tracing & Recovery practice advises foreign creditors — including trade creditors, institutional lenders, and distressed debt purchasers — on enforcement and interim relief proceedings before Russian arbitrazh courts, asset identification and tracing across the Siberian and Ural federal districts, and cross-border recovery coordination. With more than 1,000 matters handled since inception, the practice team provides direct partner involvement on every creditor-side mandate.

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

To discuss an interim relief application or enforcement matter in Russia — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

Foreign creditors who have spent months tracing assets through a Russian debtor's corporate structure only to encounter an opaque chain of nominee entities will recognise the central frustration of enforcement in this jurisdiction: knowing where the assets are is not the same as proving it in a way a Russian court will act on. Third-party disclosure orders — formal judicial mechanisms compelling banks, registrars, corporate administrators, and other information-holders to produce documents and data — have long existed in Russian civil and commercial procedure, but their practical scope has shifted considerably over the course of 2027. Courts across the arbitrazh system have applied the prevailing approach to information obligations with notably greater consistency and, in a number of circuits, greater breadth. For foreign creditors pursuing distressed Russian assets, understanding what changed and how to use these developments is now a threshold question.

The core legal framework governing third-party information obligations in Russian commercial proceedings has not been replaced by a single amending statute in 2027. What has shifted is the judicial interpretation of existing procedural rules — specifically, the conditions under which an arbitrazh court will compel a third party to produce documents or information relevant to asset identification and recovery.

Under the prevailing approach as applied through the current period, courts have increasingly accepted that the threshold for granting a disclosure order against a third party who is not a party to the underlying proceedings is lower than was commonly understood before 2025. In particular, the requirement that the requesting creditor demonstrate the third party's "possession or control" of the relevant information has been interpreted more functionally: it is sufficient to show that the third party administers, processes, or stores information that would materially assist in identifying, locating, or quantifying the debtor's assets — even where formal legal title to that information sits elsewhere.

The second significant development concerns the treatment of offshore-connected asset structures. Courts in several federal circuits have applied the Russia regulatory framework to compel disclosure from Russian-domiciled entities that act as nominees, agents, or registered representatives for offshore structures. The effect is that the Russian entity — not the offshore principal — bears the disclosure obligation, and Russian procedural enforcement mechanisms apply directly. For creditors pursuing offshore asset Russia structures, this represents a material expansion of the information-access perimeter.

A third change relates to the scope of what must be produced. Disclosure obligations that were previously understood to be limited to documents in the strict sense have, in a number of recent decisions, been extended to cover transaction data, communication metadata held by financial institutions, and information derived from know-your-customer processes maintained by financial intermediaries. This aligns Russian disclosure practice more closely with the information orders available in common-law jurisdictions, though the procedural architecture remains distinct.

"The most consequential development in 2027 is not a new statute but a shift in how courts read existing procedural rules — the practical threshold for compelling third-party disclosure has fallen, and creditors who understood the old position need to reassess." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The creditor classes most directly affected are those pursuing recovery against Russian debtors whose asset base is not held in the debtor's own name — which, in practice, describes the majority of contested enforcement positions. This includes trade creditors holding unsatisfied arbitral awards, institutional creditors with pledges over Russian assets held through intermediary vehicles, and distressed asset investors who have acquired claims against Russian entities and are now in recovery proceedings.

For creditors who have already obtained a judgment or award against a Russian debtor, the expanded information-access perimeter means that the initial asset-tracing phase of post-judgment enforcement can now reach further into the debtor's information ecosystem. Banks that hold accounts for related parties, corporate administrators who service nominee structures, and professional service firms that registered transactions on the debtor's behalf are now, under the prevailing interpretation, within the class of persons who may be compelled to produce information by court order.

Foreign creditors operating through an insolvent debtor's insolvency proceedings face a specific consideration: the insolvency administrator, as an officer of the court, has both the standing and — under current practice — an increasingly recognised obligation to pursue third-party disclosure orders as part of asset identification. Creditors who are not actively engaging with the administrator's investigative steps may find that the opportunity to shape the scope of disclosure is lost to passive observation.

The most acute risk for foreign creditors concerns limitation. Under the established approach to procedural limitation in Russian enforcement proceedings, delay in applying for disclosure orders can result in the evidence becoming inaccessible — either because the third party has legitimately destroyed records in accordance with data retention rules or because a related party has restructured the information-holding entity. Creditors who assume they have an open window for asset tracing frequently underestimate how quickly that window can close, particularly where a debtor's associates are aware that enforcement proceedings have been initiated.

If you are a foreign creditor pursuing distressed Russian assets and need to understand your current options for information access — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical priority for any foreign creditor whose recovery depends on identifying or quantifying Russian assets is to map, at the earliest available stage, which third parties are likely to hold material information and whether those parties are within the reach of Russian procedural obligations.

This mapping exercise is not straightforward. The question of which entities qualify as information-holders within the meaning of current Russian practice requires analysis of both the formal relationship between the third party and the debtor and the functional one — who in practice administered the assets, who handled the documentation, and which professional service providers have files that would be relevant. The Russia regulatory update on disclosure scope means that entities previously considered outside the reach of a disclosure order may now fall within it.

For creditors whose primary proceedings are outside Russia — enforcement of a foreign arbitral award, recognition of a foreign judgment, or an ICAC or RAC arbitration — the timing of any Russian-side asset tracing exercise requires co-ordination with the foreign proceedings. A disclosure order obtained in Russian proceedings may produce information that is relevant to, or required in, the foreign forum, and the procedural sequencing can affect admissibility and utility. The firm's Asset Tracing & Recovery practice has advised on this sequencing in a number of cross-jurisdictional enforcement matters.

Creditors who have relied on earlier assessments of what Russian disclosure mechanisms could reach — assessments made before the 2025–2027 evolution of judicial practice — should treat those assessments as potentially out of date. The practical guide to third-party disclosure orders in Russian proceedings A Practical Guide to Third-Party Disclosure Orders in Russian Proceedings covers the procedural steps in detail. The deep-dive analysis Deep Dive: Third-Party Disclosure Orders in Russian Proceedings examines the evidentiary standards courts are now applying.

Where a creditor has reason to believe that a related party or nominee entity is about to restructure or move information-holding capacity, an application for interim relief in conjunction with a disclosure order may be available. Russian courts have recognised — in the current period and with increasing consistency — that the effectiveness of a disclosure order can be undermined if advance notice of the application allows the subject to take steps that reduce its utility.

Several aspects of the 2027 development in third-party disclosure remain subject to active judicial development and cannot yet be treated as settled. Foreign creditors and their advisers should be aware of these uncertainties when building a recovery strategy that depends on information access.

The first open question concerns the geographic reach of Russian disclosure obligations. Where a Russian-domiciled entity is part of a cross-border structure and the information sought is held on servers or in records outside Russia, courts have taken divergent approaches. The prevailing view in the leading circuits is that the Russian entity's obligation to produce extends to information within its control regardless of where it is stored, but there are decisions that have taken a narrower position. Until the Supreme Court or a leading circuit issues a definitive statement, this remains a risk factor.

The second concerns the interaction between disclosure obligations and data protection legislation. Russia's data protection framework, as applied to financial and corporate information, has generated procedural friction in a number of disclosure applications where the third party has raised data protection as a ground for resisting production. Courts have generally not accepted data protection as a complete defence to a disclosure order in proceedings concerning asset recovery, but the procedural delay caused by such arguments can be significant.

The third open question — most relevant for creditors in insolvency proceedings — is the extent to which a disclosure order obtained by the insolvency administrator can be used, or independently relied upon, by an individual creditor. Current practice is not uniform, and the answer may depend on the procedural posture of the creditor within the insolvency proceedings.

Given the pace of judicial development in this area, assessments made even twelve months ago may require revision. Creditors engaged in active Russian enforcement should seek an updated analysis of the current position before drawing conclusions from earlier advice.

• A Practical Guide to Third-Party Disclosure Orders in Russian Proceedings
• Deep Dive: Third-Party Disclosure Orders in Russian Proceedings
• Asset Tracing and Recovery in Russia: Practice Overview

Q: What specifically changed in Russian third-party disclosure practice in 2027?

A: The principal change is judicial rather than statutory. Russian arbitrazh courts have applied the existing procedural framework for third-party information obligations with a materially broader interpretation of who qualifies as an information-holder and what they are required to produce. The threshold for compelling disclosure from banks, corporate administrators, and nominees has been lowered in practice. Courts have also extended the categories of information covered to include transaction data and records held by financial intermediaries as part of standard compliance processes. No single amending statute introduced these changes; they reflect an evolution in how courts apply established procedural rules.

Q: Which types of foreign creditors are most affected by these developments?

A: The developments are most relevant to foreign trade creditors holding unsatisfied judgments or arbitral awards against Russian debtors whose assets are held through nominee or related-party structures, institutional creditors with pledges over Russian assets, and distressed asset investors who have acquired claims and are now in the recovery phase. Creditors pursuing offshore-connected structures are particularly affected by the expanded interpretation covering Russian-domiciled nominees that act on behalf of offshore principals. Creditors engaged in Russian insolvency proceedings are also affected, because the insolvency administrator's disclosure obligations have developed in parallel.

Q: What should a foreign creditor do now in light of these changes?

A: Three steps are advisable. First, map the third parties who are likely to hold material information about the debtor's asset base, and assess whether any of them fall within the expanded class of information-holders under current Russian practice. Second, review the timing of any planned disclosure applications — procedural limitation and the risk of document destruction mean that delay carries concrete cost. Third, seek updated legal advice if your current strategy was built on an assessment of Russian disclosure mechanisms made before 2025. The practice position has shifted sufficiently that earlier advice may no longer accurately reflect what is available.

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 distressed asset holders on information access, cross-border enforcement, and asset identification in Russian proceedings. Working directly from Novosibirsk, the practice combines procedural knowledge of the arbitrazh and general jurisdiction courts with experience in co-ordinating Russian-side tracing work with foreign enforcement proceedings. 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

To discuss a live enforcement or asset-tracing matter in Russia, speak to our team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

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/

The Russian Supreme Court has issued clarificatory guidance on how asset repatriation obligations and currency control requirements interact — guidance that materially affects foreign creditors holding claims against Russian counterparties or seeking to enforce judgments and arbitral awards against assets located in Russia. For distressed investors and trade creditors operating across the EAEU and CIS regions, the clarification resolves several interpretive ambiguities that had previously led to inconsistent outcomes at the circuit court level, while simultaneously introducing new procedural expectations that foreign creditors must now factor into enforcement and recovery strategies.

Before the Supreme Court's clarification, the relationship between Russia's currency control regime and the obligations imposed on Russian resident companies to repatriate foreign-currency proceeds had been read inconsistently by Russian courts. In practice, the principal difficulty for foreign creditors arose at the intersection of two parallel frameworks: the statutory repatriation obligation, which requires Russian resident entities to return foreign-currency earnings from cross-border contracts to authorised Russian banks within prescribed timeframes, and the broader currency control infrastructure administered by the Federal Tax Service and the Bank of Russia, which governs permissible foreign-currency transactions by Russian residents.

The pre-clarification position created a material risk for foreign creditors seeking to enforce contractual claims or arbitral awards. Where a Russian debtor had failed to repatriate funds as required — whether because those funds were held in a foreign correspondent account, because the debtor had restructured its intercompany arrangements, or because the debtor had invoked one of the expanding categories of permitted non-repatriation — courts in different circuits applied different standards when assessing whether the failure constituted a defence to a creditor's enforcement claim, or whether it triggered a separate regulatory liability that sat alongside the creditor's rights.

The Supreme Court's clarification establishes a more unified framework. The court has confirmed that the repatriation obligation is regulatory in character and does not, by operation of law, extinguish or subordinate a creditor's underlying contractual claim. Stated differently: a Russian resident's failure to repatriate proceeds does not create a windfall defence against a foreign trade creditor's claim for the same amounts. This clarification — while it may appear to state the obvious — addresses a line of lower court decisions in which debtors had argued, with some success, that currency control non-compliance rendered the underlying debt arrangement irregular and therefore unenforceable in its original form.

Equally significant is the guidance on the treatment of assets that are subject to currency control restrictions but have not been formally frozen under a court order or government designation. The Supreme Court's position is that the existence of currency control obligations does not, in itself, constitute a basis for staying enforcement proceedings. Courts must assess whether a specific, operative restriction prevents realisation of the asset — not whether the asset is merely subject to the currency control regime in the abstract.

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The clarification has the most immediate practical relevance for three categories of foreign creditor, each of which faces a distinct aspect of the currency control framework in Russian enforcement proceedings.

The first category is trade creditors holding unpaid invoices under cross-border supply or service contracts. These creditors frequently encountered the pre-clarification uncertainty when Russian debtors raised currency control restrictions as a procedural obstacle to payment — arguing, in some cases, that the obligation to repatriate proceeds to an authorised Russian bank meant that any direct payment to a foreign creditor's account would itself constitute a currency control violation. The Supreme Court's guidance clarifies that the standard authorisation regime does not prohibit payment to foreign creditors under a valid court judgment or arbitral award, subject to the applicable licence and notification requirements administered by the Bank of Russia and the Federal Tax Service.

The second category is institutional creditors and distressed investors who have acquired Russian-law debt instruments or hold claims arising from pledge enforcement, where the underlying collateral is a Russian asset subject to currency control obligations. For these creditors, the clarification is relevant to the question of what procedural steps are required to establish that an asset is available for realisation — as opposed to being encumbered by a regulatory restriction that effectively removes it from the enforcement estate. The Supreme Court has indicated that courts must make this assessment on the facts, with the burden on the debtor to demonstrate a specific operative restriction, not merely a theoretical currency control obligation.

The third category — and the one for which the practical implications are most nuanced — is foreign creditors pursuing enforcement against Russian assets through the Russian insolvency procedure. In a Russian insolvency, currency control restrictions and repatriation obligations affecting the debtor's assets can complicate both the valuation of the estate and the priority of payments to foreign creditors. The Supreme Court's clarification, while not directed specifically at insolvency, will be applied by insolvency administrators and creditors' committees when assessing whether specific foreign-currency assets form part of the realisable estate.

For creditors who have already initiated enforcement proceedings in Russia, the clarification may be grounds to revisit earlier adverse interlocutory decisions in which the court accepted currency control arguments to justify a stay. For creditors who have not yet initiated proceedings, the clarification removes one of the more commonly cited obstacles to filing.

If you are a foreign creditor assessing enforcement options against Russian assets — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical implication of the Supreme Court's clarification is that foreign creditors who have been deterred from initiating or continuing Russian enforcement proceedings by currency control arguments now have stronger grounds to proceed. The guidance does not eliminate currency control as a relevant consideration — it remains a live compliance framework with its own regulatory consequences — but it substantially narrows the circumstances in which it can be deployed as a defence or procedural obstacle against a creditor's claim.

Three concrete steps merit immediate attention.

First, creditors who hold existing Russian court judgments or foreign arbitral awards at the recognition stage should review whether currency control arguments were used — successfully or otherwise — in prior interlocutory applications. Where a stay was granted on currency control grounds, the Supreme Court's clarification provides a basis for applying to lift the stay, and counsel should assess whether the applicable procedural window for doing so remains open.

Second, creditors considering initiating new enforcement proceedings against Russian counterparties should incorporate the Supreme Court's guidance into their pre-filing analysis. In particular, the debtor's position in relation to its own repatriation obligations — whether it has complied, obtained a permit, or accumulated regulatory liability — is now relevant not only as background context but as a factor in forecasting how the debtor is likely to respond procedurally. Where the debtor has outstanding repatriation liabilities, the Federal Tax Service may itself become a competing creditor in any subsequent insolvency, which affects the relative priority position of foreign trade creditors.

Third, creditors operating through EAEU or CIS cross-border structures should assess whether the clarification affects the enforceability of intercompany arrangements involving Russian resident entities. The repatriation framework applies to Russian residents regardless of the nationality of the counterparty — meaning that EAEU-based creditors are not exempt from the procedural consequences, even where their home jurisdiction also has currency control arrangements with Russia under the applicable bilateral or multilateral agreements.

Foreign creditors with Russian asset exposure who have not yet audited their enforcement position in light of the clarification face a timing risk that should not be underestimated. Under Russian civil procedure, limitation periods for enforcement of existing judgments and awards run continuously, and the clarification does not suspend or toll them. Creditors who defer their procedural response by more than a few months may find that the window for certain enforcement steps has narrowed materially.

For creditors who have not yet identified and mapped their Russian assets, an early step is to commission a targeted asset-tracing exercise to understand the currency control status of each identifiable asset before committing to a litigation or enforcement strategy. The firm's Asset Tracing & Recovery practice regularly advises foreign creditors at this preliminary stage, including where assets are held through interposed Russian and EAEU holding structures.

Further context on the broader repatriation landscape is set out in Navigating asset repatriation and Russian currency control and in Strategic considerations in asset repatriation for foreign creditors. For matters involving parallel insolvency risk, see the firm's Restructuring & Insolvency practice, and the Matters Hub for representative creditor-side mandates.

For a structured assessment of your Russian enforcement position in light of the Supreme Court's clarification — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Navigating asset repatriation and Russian currency control
• Strategic considerations in asset repatriation for foreign creditors
• Enforcing foreign arbitral awards in Russian courts: current procedure

Q: What specifically did the Russian Supreme Court clarify about asset repatriation and currency control? A: The Supreme Court issued guidance confirming that the statutory obligation on Russian resident companies to repatriate foreign-currency proceeds does not, by operation of law, extinguish or subordinate a foreign creditor's underlying contractual or judgment claim. The court also clarified that the mere existence of currency control obligations affecting an asset does not constitute a basis for staying enforcement proceedings — courts must identify a specific operative restriction. This resolves a line of inconsistent lower-court decisions in which debtors had used currency control arguments as a procedural shield against foreign creditor claims.

Q: Which categories of foreign creditor are most directly affected by this clarification? A: Three categories are most directly affected: trade creditors holding unpaid cross-border invoices where the debtor previously raised currency control as an obstacle to direct payment; institutional creditors and distressed investors enforcing against pledged Russian assets; and foreign creditors participating in Russian insolvency proceedings where currency control restrictions affect estate valuation and creditor priority. EAEU and CIS-based creditors are not exempt — the repatriation framework applies to Russian resident debtors regardless of the creditor's nationality or the bilateral arrangements between their home jurisdiction and Russia.

Q: What should a foreign creditor do now in light of this development? A: The immediate steps are: (1) review whether currency control arguments were used to obtain stays or interlocutory relief in any existing Russian enforcement proceedings, and assess whether those decisions can now be revisited; (2) incorporate the clarification into pre-filing analysis for any new enforcement action, including assessment of the debtor's own regulatory exposure under the repatriation framework; and (3) commission a targeted asset-tracing exercise to map the currency control status of identifiable Russian assets before committing to a strategy. Limitation periods for enforcement of existing judgments continue to run — deferring this assessment carries a concrete procedural cost.

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 trade creditors, institutional investors, and distressed debt holders on locating, preserving, and realising Russian assets. The practice regularly handles matters involving cross-border enforcement, recognition of foreign arbitral awards, and creditor-side mandates in Russian insolvency proceedings — including matters with EAEU and CIS cross-border dimensions. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with 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/

Following amendments to the Russian civil procedural framework that took effect in the period leading into 2026, foreign creditors holding English court judgments face a materially different landscape when seeking enforcement against Russian-domiciled assets. The changes do not foreclose the path to recovery, but they reconfigure it — tightening the documentary threshold, narrowing the grounds on which reciprocity can be established, and placing greater evidentiary weight on the creditor to demonstrate that an English judgment meets conditions that Russian courts now apply with increased scrutiny. For foreign creditors who have been treating a final English order as a near-automatic gateway to Russian asset recovery, the practical adjustment required is significant.

Before these amendments, the pathway for enforcing English court orders in Russia operated primarily through the reciprocity doctrine — a mechanism by which Russian arbitrazh courts could recognise and enforce a foreign court judgment in the absence of a bilateral treaty, provided the applicant demonstrated that Russian judgments were, in practice, recognised in the originating jurisdiction. English courts have a documented record of recognising Russian judgments, and this track record had, over time, formed the basis for a workable — if imperfect — route into the Russian enforcement process.

The amended framework shifts that calculus in several respects. First, it introduces heightened procedural formality requirements for the underlying judgment documentation: translations must now satisfy additional certification steps, and the certified copies of the original order must be legalised through a chain of authentication that Russian courts have indicated will be reviewed strictly. Second, and more substantively, the amended provisions introduce criteria for assessing whether the originating court had proper jurisdiction over the matter — criteria that are applied as an autonomous Russian law analysis, not by reference to the jurisdictional rules of the English court. In practice, this means that exclusive jurisdiction clauses in contracts that designate England and Wales, while enforceable as a contractual matter under English law, are now subject to an independent jurisdictional sufficiency review in Russian proceedings. Third, the amendments clarify — in a direction unfavourable to foreign creditors — the scope of Russian public policy as a ground for refusal. The public policy exception has always existed; what has changed is the interpretive guidance on its application, which courts appear to be reading more expansively.

Taken together, these changes mean that a creditor who obtained an English court order under the previous framework, and who had not yet commenced Russian enforcement proceedings, is now working against a stricter set of conditions than existed when the judgment was issued. Creditors who initiated enforcement proceedings before the amendments took effect but have not yet obtained a Russian enforcement order should seek immediate legal review of their procedural position, since courts are applying the new standards to matters still in process.

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For foreign creditors holding English judgments against Russian-domiciled debtors, the window for initiating enforcement proceedings before interpretive practice further solidifies is narrow. Make an enquiry — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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The amendment affects all holders of English court orders who have claims over assets located in Russia or held by Russian-registered entities. In terms of client profile, the impact is sharpest for three categories.

Trade creditors with outstanding judgments from English commercial court proceedings — including those arising from supply agreements, distribution contracts, or service arrangements with Russian counterparties — face the most immediate operational challenge. Their recovery route has historically depended on the reciprocity argument, and that argument is now harder to run without specialist Russian counsel who understands how the amended provisions are being applied at the circuit level.

Institutional creditors and distressed investors who have acquired English judgments as part of secondary market transactions face an additional complexity: the Russian courts may scrutinise the chain of assignment as part of the public interest review, and any gap in the assignment documentation is likely to be treated as a substantive, not merely formal, deficiency.

Financial creditors holding security over Russian offshore assets — shares in Russian operating companies held through intermediate holding structures — face a distinct problem. Even where the English order extends to the shares or the proceeds from their disposal, the enforcement in Russia of an order directed at an intermediate holding structure is subject to separate procedural requirements under Russian corporate law that the amended framework has not simplified.

Creditors who have not yet obtained a Russian enforcement order and who assumed that their English judgment would convert to a Russian writ of execution on a relatively routine basis should treat that assumption as displaced. Timelines that were previously measured in months may now extend materially, and the outcome at first instance is less predictable than it was.

Under Russian civil procedure rules, an application for recognition and enforcement of a foreign judgment must typically be filed within the applicable limitation period — a period that runs from the date the foreign judgment became enforceable, not from the date of the amendment. Foreign creditors who have been deferring their Russian enforcement application are therefore accumulating dual risk: the amended conditions now apply, and the limitation clock continues to run independently of those conditions.

The practical response for a foreign creditor holding an English court order against a Russian debtor has three components.

First, conduct a documentation audit. Review the existing English court order, its certified translations, the legalisation chain, and any prior Russian enforcement filings against the requirements of the amended framework. This audit will identify whether the documentation package meets the new formal standards or requires supplementation — a step that is easier and less costly to complete before an application is filed than after a refusal has been recorded.

Second, obtain a Russian-law jurisdictional assessment of the underlying judgment. Given that Russian courts are now applying an autonomous jurisdictional sufficiency analysis, it is necessary to evaluate — as a matter of Russian civil procedure law — whether the English court's assumption of jurisdiction over the matter is likely to be accepted by the Russian enforcement court. This is not a question that English counsel can answer without Russian law input, and it is not a question that can be deferred to the enforcement hearing without risk.

Third, identify and protect Russian assets now. The enforcement application itself takes time to process, and an unsecured creditor who has not obtained interim measures against Russian assets before that process concludes faces the risk of asset dissipation. Russian arbitrazh courts can grant interim measures — including account freezes and encumbrances on movable and immovable property — in connection with recognition proceedings. A creditor who does not apply for these measures at the outset of the Russian enforcement application may find that the debtor has legitimately restructured its Russian asset base before a writ of execution issues.

The firm's Asset Tracing & Recovery practice has handled creditor-side enforcement mandates involving cross-border judgment recognition in Russian arbitrazh courts across the Siberian and Ural federal districts. For a detailed discussion of the procedural mechanics involved, see our practitioner briefing on enforcing English court orders in Russia — practical steps and our structural analysis in the anatomy of enforcing English court orders in Russia.

Where creditors are also tracking assets through intermediate jurisdictions or offshore structures, coordination with counsel under the Restructuring & Insolvency framework may be necessary in parallel. For a broader view of what the firm handles, see the Matters page.

The amendments leave several questions that will be resolved only through accumulated court practice. Three are of direct relevance to foreign creditors.

The first is the precise outer boundary of the expanded public policy ground for refusal. The amended provisions use formulations that are broader than the previous language, but courts at the circuit level have not yet produced a consistent body of decisions that maps that boundary with precision. Creditors whose English judgments involve awards of damages calculated by reference to foreign law or foreign-currency-denominated losses should expect this to be contested ground.

The second open question concerns the treatment of English court orders made in the context of arbitration-related proceedings — including enforcement orders that give effect to arbitral awards, or anti-suit injunctions. The amended framework expressly addresses court judgments; its application to court orders that are ancillary to arbitration is not fully settled, and there is a plausible argument that these orders are subject to a different — and potentially more favourable — set of conditions under the separate framework governing recognition of foreign arbitral awards under the New York Convention, to which Russia remains a party.

The third uncertainty is whether the amended standard will be applied differently by courts in Moscow compared with courts in other federal circuits, including Siberia and the Urals. Russian arbitrazh courts at the circuit level have historically shown variation in how they apply the reciprocity doctrine, and there is no basis yet to assume that the amended provisions will be applied uniformly. Creditors whose debtors or assets are located outside the Central Federal District should factor in this circuit-level uncertainty when assessing the strength of their enforcement position.

• Enforcing English court orders in Russia — practical steps
• The anatomy of enforcing English court orders in Russia
• Asset Tracing & Recovery practice overview

Q: What specifically changed in Russian law regarding the enforcement of English court orders in 2026?

A: The amendments introduced three substantive changes. First, the documentary requirements for the judgment package — translations, certified copies, and legalisation — are now applied more strictly, and deficiencies that previously attracted only procedural correction may now result in refusal at the admissibility stage. Second, Russian courts are now conducting an autonomous assessment of whether the originating court had proper jurisdiction, applying Russian civil procedure standards rather than deferring to the English court's own jurisdictional analysis. Third, the public policy ground for refusal has been elaborated in a broader direction, with implementing guidance that courts appear to be reading as expanding — not narrowing — the categories of cases where refusal is available. Creditors who obtained English judgments before these amendments and who have not commenced Russian enforcement proceedings should treat the new conditions as applicable to their matter.

Q: Which types of foreign creditor are most affected by this change in Russian enforcement law?

A: The impact falls most heavily on three groups. Trade creditors relying on the reciprocity doctrine to enforce English commercial court orders face the sharpest immediate challenge, as the conditions underpinning that argument have been tightened. Institutional and secondary-market creditors who hold assigned English judgments face additional scrutiny of the assignment chain under the expanded public policy review. Financial creditors with security over Russian assets held through offshore intermediate structures face separate procedural requirements that the amended framework has not addressed. All three groups face the same underlying problem: an English judgment that was obtained when the enforcement conditions were less demanding is now subject to more demanding conditions on the Russian side, and that gap must be managed actively rather than assumed away.

Q: What should a foreign creditor do immediately in light of this Russia regulatory update?

A: Three steps are priority. First, review the existing documentation package — the English order, its translations, and the legalisation chain — against the new formal requirements, and identify any gaps before filing. Second, obtain a Russian-law jurisdictional assessment to evaluate whether the English court's basis for jurisdiction is likely to be accepted by the Russian enforcement court under the amended autonomous analysis. Third, consider applying for interim measures in Russian arbitrazh court at the outset of the enforcement application — not after — to reduce the risk of asset dissipation during the enforcement process. All three steps are best taken before a Russian enforcement application is filed. Once a refusal has been recorded, the procedural position becomes materially more difficult to recover.

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 — including trade creditors, institutional investors, and distressed asset holders — on recognition and enforcement of foreign court orders and arbitral awards in Russian arbitrazh courts, interim measures, and cross-border asset recovery across the Siberian and Ural federal districts. With over 1,000 matters handled since inception, the team combines deep procedural knowledge with direct partner involvement on every engagement.

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

If you hold an English court order against a Russian-domiciled debtor, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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/

The Supreme Court of the Russian Federation has, over the course of 2025 and into 2026, issued a series of clarifications that materially strengthen the procedural standing of forensic accounting evidence in commercial creditor enforcement proceedings. For foreign creditors holding claims against Russian counterparties — whether through direct litigation, pledge enforcement, or participation in insolvency proceedings — these developments alter the evidentiary calculus in asset investigations in ways that are not yet widely understood outside specialist Russian practice.

The central development concerns the treatment of expert accounting analysis — forensic accounting reports commissioned by creditors or by the court — as admissible, weighty, and in certain procedural contexts, presumptively reliable evidence in arbitrazh court proceedings. Russian courts have generally accepted accounting expert opinions for some years, but the prevailing approach before 2025 treated such evidence as one input among many, frequently subordinated to internal auditor reports or management representations submitted by the debtor entity.

The shift that courts have increasingly acknowledged in recent practice is a recalibration of that hierarchy. Under the framework that has emerged from Supreme Court guidance, creditor-commissioned forensic accounting reports — provided they meet substantive independence and methodological standards — are now accorded procedural standing comparable to court-appointed expert opinions in asset tracing disputes. In practice, this means that a foreign creditor who commissions a properly structured forensic accounting exercise before initiating proceedings is no longer confined to presenting that analysis as corroborative background material. It may serve as the primary evidential basis for claims concerning asset dissipation, value extraction, or the artificial impoverishment of a debtor entity.

The change is particularly significant in relation to distressed assets and Russian insolvency proceedings, where the identification and clawback of transferred assets is governed by a detailed preferential transaction framework. Courts across the Siberian and Ural circuits — jurisdictions where a significant proportion of industrial and resource-sector insolvencies are administered — have, in the experience of practitioners in this field, been receptive to forensic accounting methodologies that document valuation disparities, related-party flows, and asset stripping sequences.

"Russian courts' willingness to treat creditor-commissioned forensic accounting on near-equal footing with court-appointed expert analysis is a structural shift — it realigns the evidentiary power in asset tracing firmly toward a prepared creditor." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For foreign creditors investigating Russian asset positions, an early-stage forensic accounting strategy can determine whether enforcement is viable before proceedings begin. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical impact of the forensic accounting trend is not uniform across creditor types. It is most immediately relevant to three categories of foreign creditor engaged in Russian asset recovery.

The first is foreign trade creditors who are owed significant sums by Russian counterparties that have transferred assets, restructured group liabilities, or initiated insolvency proceedings in a manner that appears designed to frustrate enforcement. For these creditors, the ability to present forensic accounting analysis tracing asset movements — including intra-group transfers, below-market disposals, and cash flows to related parties — as primary evidence, rather than as background exhibits, is a material procedural advantage.

The second category is foreign institutional creditors and distressed asset investors who have acquired Russian debt at a discount and are pursuing recovery through the arbitrazh system or through creditors' committee participation in insolvency proceedings. In this context, the forensic accounting trend intersects with the transaction challenge mechanism under Russian insolvency legislation: a creditor who can demonstrate, through a properly structured forensic report, that a transaction was effected at below-market value or for the benefit of an insider will generally find that courts are more willing to engage with the clawback argument at an early stage.

The third category is foreign shareholders or joint venture partners pursuing asset recovery claims against management or controlling shareholders of Russian entities. Here, forensic accounting analysis of management accounts, related-party transactions, and dividend or capital flows serves both as the factual foundation for the claim and as a signal to the court that the claimant has investigated the position thoroughly before commencing proceedings.

Creditors who delay commissioning forensic accounting analysis — particularly in insolvency contexts where the three-year window for challenging preferential transfers is running — risk losing the procedural advantage that this development affords. The evidentiary framework rewards preparation.

The immediate practical implication of the 2026 enforcement trend is that forensic accounting should be commissioned at the investigation stage, not at the litigation preparation stage. Courts have, in the prevailing approach, proved more receptive to analysis that demonstrates a continuous investigative thread: from the creditor's initial identification of value erosion, through the forensic work, to the claim formulation. Reports produced after proceedings commence, or after key documents have been transferred outside the creditor's reach, are generally given less weight.

Three practical steps follow from this.

1. Commission an independent forensic accounting assessment as part of any Russian asset investigation before deciding whether to litigate or participate in insolvency proceedings. The assessment should document asset movements, identify related-party structures, and establish a baseline valuation against which any subsequent disposals can be measured.

1. Ensure that the forensic accounting provider meets the independence and methodological requirements that Russian courts have consistently applied. In practice, this means engaging a provider whose methodology can be explained and defended under cross-examination, and whose independence from the debtor entity and its advisers is unambiguous.

1. Coordinate the forensic accounting work with Russian legal counsel at the outset. The evidentiary strategy — how the report is introduced, what procedural vehicle is used to put it before the court, and how it interacts with any court-appointed expert — requires early decisions that cannot easily be reversed once proceedings are under way.

For foreign creditors instructing a foreign law firm in a matter with Russian asset components, the relationship between external forensic work and Russian litigation strategy is an area where early coordination with local counsel materially reduces procedural risk. Vetrov & Partners' asset tracing and recovery practice regularly advises on this interface, including the structuring of forensic evidence for use in arbitrazh court proceedings across the Siberian Federal District and beyond.

Further guidance on the procedural use of forensic accounting in Russian proceedings is set out in the firm's complementary analysis: How Russian courts approach forensic accounting evidence and Forensic accounting in Russian asset investigations: a practitioner guide.

For creditors with live Russian asset matters, early legal and forensic strategy is the primary determinant of enforcement success. Discuss your matter in confidence: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• How Russian courts approach forensic accounting evidence
• Forensic accounting in Russian asset investigations: a practitioner guide
• Asset tracing and recovery in Russia: overview for foreign creditors

Q: What specifically changed in Russian courts' treatment of forensic accounting evidence in 2025–2026?

A: The Supreme Court of the Russian Federation issued clarifications in 2025 and into 2026 that elevated creditor-commissioned forensic accounting reports to procedural standing comparable to court-appointed expert opinions in asset tracing and creditor enforcement proceedings, provided those reports meet independence and methodological standards. Previously, such reports were generally treated as corroborative background material rather than primary evidence. The shift means a creditor who commissions a properly structured forensic accounting analysis before proceedings commence can use it as the primary basis for claims concerning asset dissipation or value extraction — a significant procedural advantage in arbitrazh court proceedings.

Q: Which types of foreign creditor are most directly affected by this development?

A: Three categories are most directly affected: foreign trade creditors pursuing enforcement against Russian counterparties that have transferred assets or filed for insolvency; institutional creditors and distressed investors using the arbitrazh system or insolvency creditors' committee to challenge preferential transactions; and foreign shareholders or joint venture partners pursuing asset recovery claims against management or controlling shareholders of Russian entities. In each case, the forensic accounting development strengthens the creditor's evidentiary position in Russian court proceedings, provided the analysis is commissioned at the investigation stage rather than after proceedings begin.

Q: What should a foreign creditor do now to take advantage of the forensic accounting trend in Russian enforcement?

A: Commission a forensic accounting assessment as early as possible — before commencing litigation or lodging claims in insolvency proceedings. Ensure the provider meets Russian courts' independence and methodological requirements. Coordinate the forensic work with Russian legal counsel from the outset so that the evidentiary strategy — how the report is introduced, which procedural vehicle is used, and how it interacts with any court-appointed expert — is determined before proceedings commence. Creditors who treat forensic accounting as a litigation support exercise, rather than an investigation tool, generally find that the evidentiary weight their reports receive is lower.

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 and recovery practice advises foreign creditors, institutional investors, and foreign shareholders on the investigation, structuring, and enforcement of claims against Russian entities and individuals. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of the arbitrazh court system with direct partner involvement on every engagement. Matters span the Siberian Federal District, the Ural circuit, and cross-jurisdictional enforcement involving Russian and European assets.

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/

Regulatory update: cross-border asset recovery: coordinating Russia

For foreign creditors holding claims against Russian-domiciled debtors, the strategic picture in early 2027 has shifted in ways that demand careful procedural sequencing. Russian courts have tightened the conditions under which domestically-held assets may be encumbered during parallel foreign proceedings, and the administrative pathways through which European enforcement measures are communicated to Russian registries have become less predictable. Creditors who treat Russian enforcement as a downstream step — to be initiated once European proceedings have produced a result — risk finding that the assets they intended to recover have been dissipated, restructured, or transferred into forms that complicate recovery under Russian law.

Cross-border asset recovery involving Russian-sited assets has been affected by two converging developments. First, Russian courts have progressively narrowed the circumstances in which they will give effect to interim measures ordered by foreign courts — including asset freezes and Mareva-equivalent injunctions — absent a bilateral treaty providing for mutual recognition of such measures. For creditors pursuing enforcement through EU Member State courts or through arbitral institutions seated in Europe, this narrows the period during which a foreign interim order provides meaningful protection over assets that remain in Russian jurisdiction. The practical effect is that assets formally subject to a European freezing order may remain unencumbered under Russian law for as long as the debtor continues to hold them through Russian-registered entities.

Second, Russia's domestic insolvency and enforcement landscape has continued to evolve. The conditions under which a foreign creditor may be recognised as a participating creditor in Russian insolvency proceedings — rather than a peripheral claimant — have been clarified by the higher courts in a direction that places greater procedural burdens on creditors who have not filed within the standard claim submission windows. For distressed assets held through Russian operating companies or real estate structures, this means that a creditor who delays Russian-side action in expectation of a European judgment will frequently find itself outside the priority creditor class by the time it seeks to engage with Russian proceedings.

For creditors advising on distressed assets under Russian law, the combined effect of these developments is a compression of the effective action window. Where previously a creditor might reasonably allow six to twelve months for European proceedings to produce an enforceable instrument before turning to Russian courts, that buffer has narrowed materially under the procedural conditions now prevailing.

Creditors with Russian assets under live enforcement proceedings should review their procedural sequencing before the next filing window. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The changes bear most directly on three categories of creditor. Trade creditors holding unsecured or partially secured claims against Russian legal entities face the most immediate exposure: without a security interest registered under Russian law, their ability to assert priority over specific assets depends almost entirely on timing within insolvency proceedings, and the narrowed claim-filing windows now apply more stringently following recent judicial guidance.

Secured creditors — including those holding pledges, mortgages, or retention-of-title arrangements over Russian-registered assets — are affected in a different but equally significant way. Where the secured interest was created under foreign law and then purportedly applied to Russian-sited assets, the validity of that interest as against third parties under Russian law depends on registration formalities that were not always observed in transactions concluded under time pressure. Recent developments have reinforced the position that unregistered foreign security interests will not be given priority in Russian insolvency distributions, regardless of the foreign law governing the underlying agreement.

Institutional creditors — including those holding distressed debt acquired from trade creditors or banks — face a further complication arising from the EAEU dimension. Russia's membership of the Eurasian Economic Union means that creditors operating through entities established in Armenia, Belarus, Kazakhstan, or Kyrgyzstan may have access to enforcement pathways that differ from those available to creditors operating through EU-incorporated entities. The practical accessibility of those pathways in practice, however, varies considerably and should not be assumed without jurisdiction-specific analysis.

The CIS multilateral framework for legal assistance also remains technically operative between Russia and a number of CIS member states, providing treaty-based mechanisms for recognition of court decisions and service of process that are not available between Russia and most EU jurisdictions. For creditors with structural flexibility in how they hold or pursue their claims, this treaty architecture is worth assessing at the strategy-setting stage, before proceedings are commenced.

The central practical implication of these developments is that cross-border asset recovery involving Russian-sited assets requires earlier and more granular coordination between Russian-side counsel and European proceedings counsel than has historically been the case. Three action areas warrant immediate attention.

First, creditors should assess whether any Russian-side interim measures — including asset freezes under Russian civil procedure, security over specific assets, or applications to preserve claim rights in anticipated insolvency — are available and should be pursued in parallel with, rather than sequentially after, European proceedings. Russian courts retain the jurisdiction to grant interim asset protection measures in support of substantive claims, and early applications can create a layer of protection over Russian-sited assets that does not depend on the recognition of any foreign order.

Second, creditors who have not yet registered claims in Russian insolvency proceedings — or who are monitoring a debtor's financial position without yet having filed — should obtain a current assessment of the debtor's status under Russian insolvency registers. The initiation of Russian insolvency proceedings, once published, triggers filing windows that are strictly enforced; a creditor that misses the initial window is relegated to a lower priority class regardless of the size or seniority of its claim. For creditors tracking distressed assets in Russian operating companies, this monitoring function is not optional.

Third, where assets are held through multi-jurisdictional structures involving both Russian entities and entities in EAEU or CIS member states, the enforcement strategy should be mapped across all relevant jurisdictions simultaneously. Enforcement sequencing that optimises recovery in one jurisdiction can inadvertently create estoppel risks, asset dissipation opportunities for the debtor, or priority conflicts in another. Coordinating these elements requires Russian counsel who is actively involved in the European-side strategy, not merely notified of developments after the fact.

For creditors who engaged Russian counsel at an early stage of their recovery effort, these developments reinforce the value of that approach. For creditors who have not yet established a Russian counsel relationship, the procedural developments of late 2026 and early 2027 make that a more pressing priority than it may have appeared twelve months ago.

If you are managing a cross-border asset recovery matter involving Russian-sited assets, our team is available to assess the Russian-side procedural position. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Q: What specifically has changed in the way Russian courts treat European interim measures targeting Russian-sited assets?

A: Russian courts have tightened their approach to giving effect to foreign interim measures — including asset freezes and injunctions issued by EU Member State courts — where no bilateral treaty provides a direct mechanism for recognition of such orders. In practice, this means that a European freezing order does not automatically prevent a debtor from dealing with Russian-sited assets. A separate Russian-side application is required to encumber those assets under Russian procedural law, and that application must be grounded in a substantive Russian-law claim or recognised insolvency position. The change does not eliminate the availability of Russian interim measures; it reinforces the importance of pursuing them independently and in parallel with foreign proceedings, rather than assuming that a foreign order provides coverage.

Q: Which types of foreign creditor are most exposed to these procedural developments?

A: Unsecured trade creditors are most immediately exposed, as their recovery position in Russian insolvency proceedings depends almost entirely on timely claim filing. Secured creditors whose security interests were created under foreign law but not registered under Russian formalities face a separate vulnerability: Russian courts and insolvency administrators are likely to treat such interests as unregistered and therefore subordinate in any distribution. Institutional creditors holding acquired distressed debt should pay particular attention to the EAEU and CIS treaty landscape, which may offer enforcement pathways not available through standard EU-Russia enforcement channels. In all three categories, the common factor is that delay in establishing a Russian-side procedural position compounds the risk materially.

Q: What is the first practical step a creditor should take when it identifies Russian-sited assets in a cross-border recovery matter?

A: The most important first step is obtaining a current legal assessment of the debtor's status under Russian law — specifically, whether insolvency proceedings have been initiated or are imminent, what assets are registered in Russian registries, and what interim measures are available under Russian civil procedure. This assessment should be conducted by Russian counsel who can advise not only on the current position but on the interaction between Russian-side procedural options and the strategy being pursued in European proceedings. Early engagement allows the creditor to pursue Russian interim measures and claim filings within the applicable windows, rather than reactively after those windows have closed. Creditors who have already commenced European proceedings without Russian counsel in place should treat this as a gap to close without delay.

• Foreign creditors and cross-border asset recovery in Russia
• The law and practice of cross-border asset recovery in Russia
• Asset Tracing & Recovery — Practice Overview

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 and recovery practice advises foreign creditors, institutional investors, and distressed-debt holders pursuing recovery through Russian courts and insolvency proceedings. With over 1,000 matters handled since inception, the team combines deep knowledge of Russian enforcement procedure with direct partner involvement on every engagement, including matters requiring coordination across EAEU and CIS jurisdictions.

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 — Asset Tracing & Recovery, Vetrov & Partners vetrovpartners.com/razina/

The amended rules governing access to Russian corporate registry data — changes that took effect progressively through 2026 and are now fully operative in early 2027 — have materially altered how British creditors can locate, identify, and trace assets held through Russian-registered entities. For a British creditor pursuing an unpaid claim, a judgment debt, or a cross-border enforcement strategy, understanding what Russian corporate registry searches now can and cannot yield is no longer optional groundwork. It is the threshold question for any viable recovery plan.

For many years, Russia's principal commercial entity register — commonly referred to by its Russian abbreviation EGRUL — operated on a broad public-access model. A foreign creditor's adviser could extract substantial information about a Russian company's registered address, ownership structure, directors, and declared share capital through freely available searches. That model has been substantially qualified.

The reforms that took effect through 2026 introduced tiered access to registry information. Certain categories of data — particularly information concerning beneficial owners, nominee structures, and the identity of individuals exercising indirect control — are no longer retrievable through standard public-access channels. Access to this data now requires either a demonstrated legal interest (such as pending litigation or a confirmed creditor status in insolvency proceedings) or submission through a regulated intermediary with appropriate professional standing. The practical consequence is that the volume of information obtainable from a routine EGRUL search has contracted at precisely the point where that information is most valuable to a creditor.

A second significant development concerns the Fedresurs — the Federal Resource for legally significant disclosures, which functions as the Russian equivalent of a corporate insolvency and significant-event register. Updated rules have revised both the categories of disclosures that Russian entities are required to make and the timelines within which those disclosures must appear. For British creditors, this register has become a more reliable upstream indicator of a debtor's distress than the entity register itself, but only where the creditor has the procedural means to monitor it systematically.

"[Q: What specifically changed in Russian corporate registry access rules?

A: The principal change is a shift to tiered access. Standard public searches of EGRUL now return less information about ownership and control than they did before 2026. Data concerning beneficial owners and indirect control arrangements requires a demonstrated legal basis to access — such as active litigation or insolvency creditor status. Separately, Fedresurs disclosure obligations were revised in scope and timing, making that register more informative for creditors tracking debtor distress.]"

— Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For British creditors assessing what a Russian corporate registry search can yield in their specific recovery context, the starting point is an accurate picture of what the current access rules permit. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The impact of the tiered-access model is not uniform. It is most acute for British creditors in three specific positions.

First, creditors at the pre-litigation stage — those who are gathering information about a Russian counterparty before commencing proceedings — now find that the public registry yields less about the entity's ownership chain than it once did. A creditor investigating whether assets exist worth pursuing cannot assume that a standard search will reveal the full picture of who controls the Russian entity or what assets that entity holds indirectly through related structures.

Second, British creditors who obtained a judgment or arbitral award outside Russia and are now seeking to enforce in Russia face a structurally different information environment than existed before these reforms. The enforcement process in Russian courts requires a creditor to identify assets with reasonable specificity. Where the debtor has arranged its affairs to rely on the reduced visibility of the current registry model, the burden on the creditor to obtain supplementary information through court-supervised discovery mechanisms has increased.

Third, creditors participating in Russian insolvency proceedings as foreign trade creditors may find that the revised Fedresurs disclosure timeline creates windows during which a debtor's material transactions are not yet visible on the register. Creditors who delay initiating enforcement proceedings in anticipation of a cleaner information picture risk losing priority in an insolvency that the debtor may file unilaterally and on its own timeline — a risk that the 2026 reforms have amplified rather than reduced.

There is, however, a countervailing development that benefits creditors with active legal proceedings. Russian courts have increasingly accepted applications by creditors in pending proceedings to compel disclosure of registry and beneficial ownership information directly from registrar authorities. This court-assisted route was available before 2026, but procedural clarifications issued in that period have reduced some of the uncertainty about the threshold a creditor must meet to obtain such an order. For British creditors who have already commenced litigation or enforcement in Russia, this route deserves early attention.

The practical response to the 2026 registry reforms is not to abandon corporate registry searches as an intelligence source — it is to understand precisely what each route of access will and will not yield at the specific stage of the creditor's recovery strategy.

A creditor at the investigation stage should commission a layered search: a standard public-access EGRUL search combined with a systematic Fedresurs review and, where the debtor entity is a member of a wider corporate group, cross-referenced searches of related entities. The combination frequently reveals more than any single search in isolation, even under the tiered-access model.

A creditor with active proceedings in Russia — whether enforcement of a foreign judgment, recognition of an arbitral award, or participation in insolvency — should consider making an application for court-assisted disclosure at the earliest procedurally permissible point. The revised procedural landscape means that delay in making this application carries a higher cost than it did before the 2026 reforms.

For British creditors instructing Russian counsel for the first time, it is worth noting that the technical standard for formulating a court-assisted disclosure request has become more exacting since 2026. The request must identify the category of information sought, the legal basis for the creditor's interest, and the relevance of that information to the pending proceedings with a degree of specificity that was not always required under prior practice. A request that would have been sufficient two years ago may now be insufficient. Instructing counsel with current familiarity with post-reform registry practice is a material consideration.

For matters where the Russian debtor holds assets through offshore structures with Russian operating entities beneath them — a pattern that remains common in creditor recovery work — the interaction between the tiered-access model and the separate rules governing beneficial ownership disclosure deserves specific analysis. Those rules were also revised in 2026, and the relationship between the two regulatory changes is not always intuitive.

Further analysis of the procedural options for British creditors at each stage of recovery is set out in A practical guide to Russian corporate registry searches and in the related briefing on Russian corporate registry searches for asset tracing.

If you are a British creditor assessing enforcement options against a Russian entity, or instructing local counsel for the first time following the 2026 registry reforms, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The 2026 reforms left several questions that courts and registrar authorities have not yet resolved consistently.

The threshold for demonstrating a "legitimate legal interest" sufficient to unlock tiered-access data varies across different courts and registry administrative units. Some administrative decisions have taken a strict approach, requiring documentary evidence of pending proceedings before granting access. Others have accepted a lower evidentiary threshold where the creditor's claim is at a pre-action stage but the need for the information is demonstrably connected to an imminent legal step. British creditors should not assume that a single standard applies across all circuits.

The revised Fedresurs disclosure obligations also raise timing questions that have not been definitively resolved. The point at which a disclosure obligation is triggered — particularly for transactions that a debtor enters into when insolvency is foreseeable but not yet filed — has been subject to differing interpretations in the Siberian and Ural circuits. This matters for British creditors because transactions that are not yet visible on Fedresurs may still be susceptible to challenge under Russian insolvency law once proceedings commence, but the window for identifying them is narrow.

Finally, the 2026 reforms interact with Russia's position as a member of the Eurasian Economic Union and the Commonwealth of Independent States. Cross-border information-sharing arrangements within those frameworks were not amended to reflect the tiered-access model, creating a degree of inconsistency in what a creditor can access about Russian entities operating across EAEU jurisdictions. The practical implications of this inconsistency are still being worked through in practice.

• A practical guide to Russian corporate registry searches
• Russian corporate registry searches for asset tracing
• Asset Tracing & Recovery in Russia

Q: What specifically changed in Russian corporate registry access rules in 2026?

A: The central change is a move from broad public access to tiered access. Standard searches of the EGRUL registry now return less data about beneficial ownership and indirect control arrangements than they did before 2026. Accessing this category of information now requires a demonstrated legal interest — such as active litigation or confirmed creditor status in insolvency proceedings — or submission through a regulated professional intermediary. Separately, Fedresurs disclosure obligations were revised in both scope and timing, making that register a more reliable indicator of debtor distress in certain contexts, though the timing of disclosures has also created new gaps that creditors need to account for in their recovery strategies.

Q: Which British creditors are most affected by the 2026 registry reforms?

A: Three categories of British creditor face the most significant practical impact. First, creditors at the pre-litigation investigation stage, who now find that standard public searches yield less information about ownership and control than previously. Second, creditors enforcing a foreign judgment or arbitral award in Russia, who face a higher burden in identifying assets with the specificity Russian courts require. Third, creditors participating in Russian insolvency proceedings, who may find that the revised Fedresurs disclosure timeline creates gaps in the information available at the point of creditor registration. Creditors with active proceedings in Russia are, however, better placed than before to obtain court-assisted disclosure orders, following procedural clarifications issued in 2026.

Q: What practical steps should British creditors take in light of these developments?

A: Three steps are advisable. First, commission a layered search combining public EGRUL data with a systematic Fedresurs review and, where relevant, cross-referenced searches of related entities in the same group — the combination typically reveals more than any single search. Second, if proceedings are already on foot in Russia, make an application for court-assisted disclosure at the earliest procedurally permissible stage; delay now carries a higher cost than it did before 2026. Third, ensure that any Russian counsel instructed has current experience of post-reform registry practice — the technical standard for court-assisted disclosure requests became more demanding in 2026, and a request that would have been sufficient under prior rules may now be insufficient.

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 — including British trade creditors, institutional investors, and enforcement counsel — on locating and recovering assets held through Russian entities and cross-border structures. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of Russian registry and insolvency practice with 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/

Amendments to the regulatory framework governing access to the Rosreestr property register, which consolidated through court practice and administrative guidance in the period leading up to mid-2027, have materially shifted the investigative options available to creditors pursuing insolvency estates in Russia. Where the register was once accessed through informal channels and tolerant procedural norms, courts and the Federal Service for State Registration, Cadastre and Cartography (Rosreestr) have moved toward a more structured, court-supervised model — one that rewards creditors who understand the system and penalises those who do not act early. For foreign trade creditors and institutional investors with claims against Russian entities in insolvency proceedings, the practical implications are immediate.

The central development through the first half of 2027 concerns the formalization of creditor access to Rosreestr extract data in the context of insolvency proceedings. Previously, creditors — and the insolvency administrators acting on their behalf — could obtain property register extracts with relative procedural ease, either through direct administrative requests or through the insolvency administrator's statutory information-gathering powers. Court supervision of these requests was light, and administrators routinely compiled comprehensive Rosreestr profiles of debtor estate assets without encountering substantive procedural objections.

That position has evolved. Court practice across a number of circuits has increasingly required that requests for expanded Rosreestr data — particularly those covering historical ownership records, encumbrance chains, and title transfers in the run-up to insolvency — be supported by a specific procedural basis: either an express court order within the insolvency proceedings, or a formally recognised request submitted by the administrator through the defined channel set out in the applicable procedural rules. The practical effect is that informal or broadly framed requests now attract resistance from Rosreestr offices, and the resulting extracts may be incomplete or delayed.

Alongside this procedural tightening, Rosreestr has introduced updated guidance on the scope of information that may be disclosed in relation to individuals who are connected to an insolvency estate — beneficial owners, related-party transferees, and co-owners of assets that passed through the estate before the insolvency filing. Creditors seeking to trace assets that left the debtor's balance sheet in the three years preceding insolvency — the window relevant for challenging preferential and fraudulent transfers under Russian insolvency legislation — now face a more granular disclosure framework. Some categories of historical data require separate procedural steps, and the timing of those steps relative to the insolvency timeline matters considerably.

"

For creditors with claims against Russian insolvency estates who need to assess asset-tracing options under the updated Rosreestr framework — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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The creditors most directly affected by these developments are those whose claims arise from trade relationships with Russian counterparties — foreign manufacturers, commodity suppliers, and service providers whose Russian distributors or purchasers have entered or are approaching insolvency. Where the debtor entity holds registered real estate, machinery on cadastral record, or rights registered through Rosreestr-adjacent systems, the register remains the primary publicly accessible investigative resource available to a creditor in the early stages of insolvency.

The critical concern for foreign creditors is timing. Under Russian insolvency legislation, creditors who delay initiating enforcement proceedings or fail to register their claims within the statutory period risk losing their position in the creditor priority queue — a window that, once closed, cannot be reopened by subsequent diligence, however thorough. The Rosreestr property register in Russia has historically served as an early-warning tool: a creditor who interrogates it promptly upon learning of a debtor's financial distress may identify encumbrances, recent disposals, or undisclosed co-ownership arrangements that alter the recovery picture materially. Under the evolving practice described above, accessing that intelligence requires earlier and more deliberate procedural action than was previously the case.

For institutional investors holding secured claims — where the Rosreestr register directly underpins the validity and enforceability of the security interest itself — the developments are equally significant. The extract confirming a pledge, mortgage, or right of lease registered against an asset is the foundational document in any enforcement sequence. If the procedural steps to obtain updated and certified extracts are misunderstood or delayed, enforcement proceedings may be founded on stale or incomplete register data, which Russian courts have treated with increasing scrutiny.

Foreign creditors instructing Russian insolvency counsel for the first time frequently underestimate the extent to which the Rosreestr property register in Russia functions not merely as a title registry but as an investigative instrument — one whose utility is bounded by the procedural steps taken to access it correctly and in time.

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Firms advising clients with claims against Russian insolvency estates will benefit from confirmed local counsel before the creditor registration deadline becomes a live constraint — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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The practical guidance that follows from the 2027 developments is sequential and time-sensitive.

First, any foreign creditor that has received notice of, or has reason to suspect, insolvency proceedings against a Russian counterparty should commission a Rosreestr property register search at the earliest opportunity — before the insolvency proceedings have formally consolidated the estate and before the procedural framework governing administrator requests begins to limit third-party access. This is particularly important where the debtor is a legal entity holding registered real estate or where there is reason to believe assets were transferred to connected parties in the period preceding insolvency.

Second, creditors should not assume that the insolvency administrator will conduct this investigation on their behalf, or that the administrator's Rosreestr extracts will be shared proactively with all registered creditors. The administrator's obligations under Russian insolvency legislation run to the collective creditor body; individual creditors with specific recovery interests — particularly foreign creditors whose claims may be smaller in aggregate but whose legal strategies may differ from those of the major domestic creditors — need their own picture of the asset landscape.

Third, where a creditor has grounds to challenge a transfer as preferential or otherwise voidable, the Rosreestr records establishing the chain of title and the timing of encumbrances are central evidentiary items. Russian courts have consistently required that transfer-challenge claims be supported by documented register evidence. Assembling that evidence through the correct procedural channels — rather than relying on informally obtained extract copies — is now more important than it was twelve months ago.

For cross-border matters where the debtor's assets span more than one jurisdiction, Asset Tracing & Recovery counsel who can coordinate the Russian Rosreestr investigation with parallel searches in other registries will be essential. The firm's practice in this area covers the full chain from initial asset identification through to enforcement proceedings before Russian courts, including the Siberian and Ural circuits where a material proportion of the firm's insolvency and asset-tracing matters arise.

See also: The Law and Practice of Rosreestr Property Register Searches in Russia and Rosreestr Property Register: Practical Guide for Foreign Creditors.

"— Elizaveta Razina, Senior Lawyer, Practice Lead — Asset Tracing & Recovery, on the significance of procedural timing: 'In insolvency estate matters, the value of Rosreestr data degrades rapidly as proceedings progress — creditors who access it correctly and early consistently recover more.'"

• The Law and Practice of Rosreestr Property Register Searches in Russia
• Rosreestr Property Register: Practical Guide for Foreign Creditors in Russian Insolvency
• Asset Tracing and Recovery in Russia: Overview for Foreign Creditors

Q: What specifically changed in how Rosreestr is used in Russian insolvency estate proceedings in 2027?

A: The principal change is procedural: courts and Rosreestr offices have consolidated around a model that requires a formal procedural basis — typically a court order or a properly constituted administrator request — for obtaining expanded register data, particularly historical ownership records and encumbrance chains relevant to transfer-challenge proceedings. Informal or broadly framed requests that were previously tolerated now routinely attract resistance or produce incomplete extracts. Separately, guidance on disclosure of data relating to individuals connected to the estate — co-owners, related-party transferees, beneficial owners — has become more granular, requiring creditors to plan their investigative steps in advance and in the correct sequence.

Q: Which foreign creditors are most affected by these changes to the Rosreestr property register in Russia?

A: Foreign trade creditors — manufacturers, commodity exporters, and service providers whose Russian counterparties have entered or are approaching insolvency — are the most immediately affected, particularly where the debtor holds registered real estate or other cadastrally recorded assets. Institutional investors holding registered security interests over Russian real property are also significantly affected, since the enforceability of their security depends on the accuracy and currency of the Rosreestr extract underpinning the encumbrance. Creditors whose claims are smaller but whose recovery strategies diverge from those of the majority domestic creditor body — a common situation for foreign creditors in Russian insolvency proceedings — have the most to lose from delays in accessing register data independently.

Q: What should foreign creditors do now to protect their position in a Russian insolvency estate?

A: The immediate priority is to commission a Rosreestr property register search before insolvency proceedings have fully consolidated, and to do so through counsel who can access the register via the correct procedural channel — not via informal extract services. Creditors should also register their claims within the statutory deadline under Russian insolvency legislation and should not assume the insolvency administrator will share register data proactively. Where there is reason to believe assets were transferred to connected parties before the insolvency filing, transfer-challenge proceedings require documented register evidence assembled through proper channels. Taking these steps early — before the procedural framework contracts around the administrator's exclusive access — is now materially more important than it was in prior years.

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

The firm's Asset Tracing & Recovery practice advises foreign trade creditors, institutional investors, and distressed asset purchasers on identifying, tracing, and recovering assets held within Russian insolvency estates — including through Rosreestr register investigations, transfer-challenge proceedings, and coordinated enforcement across the Siberian and Ural circuits. With over 1,000 matters handled since inception, the team works on a partner-direct basis 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/

Following amendments to Russian court procedure governing the disclosure of financial information that took effect in stages during 2026 and 2027, foreign creditors – and Turkish trade creditors in particular – now face a materially different procedural landscape when tracing bank accounts and financial flows in Russia. What had previously been an opaque, multi-step process relying heavily on informal judicial cooperation has been reorganised under a more formalised framework. For Turkish businesses holding unrecovered debts against Russian counterparties, understanding what changed, which courts now have jurisdiction over financial disclosure requests, and what evidentiary burden applies is not an academic exercise – it is the practical precondition for any effective recovery strategy.

Russian procedural rules on financial disclosure have historically operated through two primary channels: interim relief applications (обеспечительные меры) securing information about a debtor's bank accounts pending or during proceedings, and separate post-judgment disclosure mechanisms available once an enforcement order has been obtained. The two channels were subject to different standards, different courts, and significantly different timelines – a complexity that foreign creditors, unfamiliar with Russian procedural bifurcation, routinely underestimated.

The changes that have emerged from court practice and implementing guidance over 2026–2027 have, in the prevailing interpretation, consolidated the threshold for granting financial disclosure orders. Russian arbitrazh courts – which handle commercial disputes involving foreign creditors – have in most circuits applied a more structured proportionality analysis when considering account disclosure requests. Under the standard now developing across the Siberian and Ural circuits, among others, a creditor must demonstrate a prima facie basis for the debt claim, a sufficiently concrete risk of asset dissipation, and a defined scope for the disclosure sought. Blanket disclosure requests covering all accounts and affiliated entities have generally not been sustained on appeal. Courts have instead required creditors to particularise the financial flows they seek to trace and to provide corroborating evidence – correspondent banking records, transaction confirmations, export documentation – that justifies the scope of the order sought.

The second development concerns the treatment of information received through international legal cooperation channels. Russia and Turkey maintain bilateral legal assistance arrangements, and Russian courts have in recent periods been willing to give weight to financial records provided through those channels, provided they are properly legalised or apostilled and accompanied by certified translations into Russian. However, the evidentiary weight accorded to such records has varied by circuit, and at least one cassation-level decision in the past year has underlined that foreign banking records must meet the same admissibility standards as domestic documentary evidence – a requirement that catches Turkish creditors unprepared when they have relied on English-language bank statements without formal certification.

"The practical shift we observe in 2026–2027 is not a liberalisation of Russian disclosure procedure – it is a rationalisation. Creditors who come with precise, documented claims fare markedly better than those seeking broad disclosure orders without evidentiary preparation." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

For Turkish creditors assessing how these procedural changes affect a live recovery matter in Russia, the evidentiary threshold is the point at which preparation either opens or forecloses effective relief – make an enquiry at info@vetrovpartners.com or reach the team directly on WhatsApp / Telegram: +7 (983) 510-38-76

The procedural changes described above affect Turkish creditors across a range of commercial relationships with Russian counterparties, but three categories of Turkish businesses face the most direct exposure.

Turkish export trade creditors – companies that supplied goods or services to Russian importers and hold unpaid receivables – are the most numerically significant group seeking to trace bank accounts and financial flows in Russia. For these creditors, the new particularisation requirement means that account disclosure requests must typically be anchored to specific transaction flows: named correspondent bank routes, identified payment instructions, or traceable shipment records. Turkish creditors who dealt in cash or quasi-cash arrangements, or who transacted through complex intermediary chains, will find the evidentiary preparation more demanding. The practical consequence is that disclosure proceedings that might previously have been initiated within weeks of a default may now require a preparatory phase of two to three months – even before a court application is made.

Russian-Turkish joint venture creditors – where a Turkish partner holds claims against a Russian co-venturer arising from governance failures or misappropriation – face a related but distinct challenge. Tracing bank accounts and financial flows in Russia in this context often requires combining an asset disclosure order with a derivative action or shareholder remedy. Russian courts have, in a number of recent matters, insisted on sequencing these applications separately, which extends the timeline and complicates interim protection of the assets being traced.

Turkish institutional creditors – banks and financial institutions that have extended credit to Russian borrowers under agreements governed by Russian law or with Russian jurisdiction clauses – are generally the best-positioned to meet the new evidentiary threshold, because their documentation standards are already high. The principal challenge for this group is currency: Russian courts have tightened the requirement that financial information underlying a disclosure application be current, with records more than three months old typically requiring supplementation before an application will be sustained.

Foreign creditors who delay initiating disclosure proceedings risk a narrowing of available assets: Russian counterparties who anticipate enforcement have, in documented patterns of practice, transferred account balances and restructured financial flows through affiliated entities within a matter of weeks of a default event becoming apparent. The window between a creditor recognising a default and a court granting effective financial disclosure protection is operationally critical.

Turkish creditors who have identified a default or are monitoring a Russian counterparty in financial difficulty should treat the evidentiary preparation for a disclosure application as an immediate priority, not a post-judgment step – make an enquiry at info@vetrovpartners.com or contact the team via Telegram: t.me/vitvetcom

The procedural changes of 2026–2027 do not close the route to tracing bank accounts and financial flows in Russia – but they do require Turkish creditors to approach the process differently than in prior years. Three practical steps follow from the current court practice.

First, Turkish creditors should undertake a pre-application evidence audit before instructing local counsel to file. This means collecting and certifying all documentary evidence of the debt claim and the relevant financial flows – export contracts, invoices, shipping documents, correspondence, and any banking records reflecting payments or attempted payments. Where documents are in Turkish or English, certified Russian translations must be prepared in advance. Evidence that arrives piecemeal after a disclosure application has been filed does not cure threshold deficiencies in most circuits.

Second, creditors should define the scope of the disclosure sought with specificity. Russian courts in the current period are not receptive to omnibus requests. A well-prepared application identifies the specific accounts, entities, or transaction routes that the creditor has reason to believe are involved, and explains why disclosure of those particular flows is necessary. This specificity requires advance intelligence – which may itself require preliminary steps with the Asset Tracing & Recovery practice before an application is drafted.

Third, Turkish creditors should consider the relationship between financial disclosure proceedings and parallel steps under the Russia–Turkey bilateral cooperation framework. For matters where the Russian counterparty has assets or financial relationships in both jurisdictions, a coordinated approach – initiating Russian court proceedings while simultaneously preserving information channels under bilateral arrangements – typically produces better outcomes than a sequential strategy. This is particularly relevant where the Turkish creditor holds assets of the Russian party in Turkey that may be available for set-off or reciprocal enforcement.

For further context on the underlying procedural framework, our analysis of navigating bank account and financial flow tracing in Russia provides a detailed procedural walkthrough. A deeper examination of the evidence standards applicable at each stage is available in our deep-dive on tracing bank accounts and financial flows.

Q: What specifically changed in Russian court practice on financial disclosure in 2026–2027?

A: The principal development is the consolidation of the evidential threshold for financial disclosure orders in Russian arbitrazh courts. Courts have, in the prevailing interpretation across most circuits, moved from a relatively permissive standard – where a creditor's assertion of a debt claim was sufficient to support a broad disclosure request – to a structured proportionality analysis requiring the creditor to identify specific financial flows, demonstrate a concrete risk of dissipation, and provide corroborating documentary evidence. Blanket disclosure requests covering all accounts and affiliated entities have generally not been sustained on appeal. The treatment of foreign banking records has also tightened: Turkish-language or English-language documents must be formally certified and translated before they will be accorded evidentiary weight.

Q: Which Turkish creditors are most directly affected by these changes?

A: Turkish export trade creditors holding unpaid receivables against Russian importers face the most immediate operational impact, because the new particularisation requirement transforms what was previously a reactive step into a proactive, evidence-intensive process. Turkish joint venture creditors and institutional lenders are also affected, though typically better positioned to meet the documentation threshold. In all three categories, the defining variable is how quickly the creditor can assemble and certify the evidentiary package needed to sustain a focused disclosure application. Creditors whose documentation is in order at the point of default – before proceedings are initiated – have a materially stronger position than those who seek to reconstruct the evidentiary record after the fact.

Q: What should Turkish creditors do now?

A: Three immediate steps are advisable. First, conduct a pre-application evidence audit: identify and certify all documents evidencing the debt claim and the relevant financial flows, with certified Russian translations prepared in advance. Second, define the scope of the disclosure application with specificity – the counterparty accounts, entities, or transaction routes to be covered – rather than seeking omnibus relief. Third, consider whether parallel steps under the Russia–Turkey bilateral legal assistance framework are available and whether coordinating those steps with Russian court proceedings would strengthen the overall recovery strategy. Engaging Russian counsel before a formal default is declared – or at the earliest stage thereafter – provides the greatest operational flexibility.

• Navigating bank account and financial flow tracing in Russia
• Deep-dive: tracing bank accounts and financial flows in Russia
• Asset Tracing & Recovery practice overview

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 and recovery practice advises foreign creditors – including Turkish trade creditors, institutional lenders, and investors with Russian exposure – on financial disclosure proceedings, enforcement, and cross-border recovery strategy. With offices in Novosibirsk, the team operates at UTC+7, providing a morning overlap with Turkish business hours and evening availability for European co-counsel coordination. Partner-direct involvement is maintained on every tracing and recovery engagement; matters are not delegated to fee-earners without senior sign-off.

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/

Russian trade relationships with Turkish counterparties have grown substantially over recent years, and so has the volume of disputed debts routed through intermediate holding structures. In 2026, Russian courts have begun applying a noticeably stricter evidential and doctrinal approach to unwinding shell company structures with Russian elements — a shift that directly affects the recovery options available to Turkish creditors who are attempting to reach Russian-held assets sitting behind layers of intermediate entities.

The core shift entering 2026 relates to how Russian courts assess the legal substance of intermediate holding structures interposed between a foreign creditor and the Russian-based assets that creditor is attempting to reach. Previously, the burden of demonstrating that a structure constituted a vehicle designed to insulate assets from legitimate claims fell heavily on the claimant. Courts applied a formal analysis: if the intermediate entity was properly registered, had documented corporate formalities, and engaged in at least nominal commercial activity, it was generally treated as a genuine legal person entitled to the protections that flow from separate corporate personality.

That approach has shifted. Russian courts — particularly at the appellate and cassation levels — have moved towards a substance-over-form analysis that looks behind registration and formal corporate records. The inquiry now focuses on whether the entity in question exercised genuine economic independence, maintained its own management infrastructure, bore actual commercial risk, and engaged in transactions at arm's length with the Russian operating company below it. Where those criteria are not met, courts have shown a willingness to treat the intermediate structure as transparent — effectively attributing the Russian assets directly to the creditor's claim horizon.

For Turkish creditors, this development is double-edged. It creates a pathway to Russian assets that may previously have appeared unreachable behind an offshore holding layer. It also means that Russian courts are equally capable of applying the same substance-over-form lens to structures in which the Turkish creditor's own claim is mediated through an intermediate entity — a procedural posture that demands careful pre-litigation review.

If you are a Turkish creditor assessing your recovery options against Russian-held assets in a shell structure, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The creditors most immediately affected by this shift in Russian court practice fall into three broad categories.

The first is Turkish trade creditors holding overdue receivables from Russian counterparties — typically in sectors where bilateral trade volumes have been highest: construction materials, textiles, agricultural inputs, and light manufacturing. Where the Russian debtor has interposed a holding structure between itself and its operating assets, the 2026 doctrinal shift creates an opportunity to pierce that layer in enforcement proceedings, provided the creditor can adduce evidence of the structure's non-commercial purpose.

The second category is Turkish investors or joint venture partners who entered Russian arrangements using intermediate holding vehicles — often Cyprus, BVI, or UAE-registered entities — as the nominal party to the Russian investment agreement. Where the relationship has broken down and the Turkish party is seeking to enforce contractual rights or recover a capital contribution, the unwinding of the shell structure becomes a threshold question in any Russian proceedings. Courts are now more receptive to arguments that the intermediary was merely an instrument of convenience rather than a genuine party.

The third, and most complex, category comprises Turkish creditors involved in insolvency proceedings where a Russian debtor has already filed. Under Russian insolvency legislation, the administrator's power to challenge and unwind transactions entered into within prescribed look-back periods is well established. What 2026 practice clarifies is that this unwinding power extends with increasing confidence to transactions structured through intermediate entities — meaning that a Russian insolvency administrator may now more readily unwind asset transfers that passed through an offshore shell before they left the Russian debtor's economic orbit.

"[Quote]" — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement & Asset Protection, Vetrov & Partners

Turkish creditors who delay initiating recovery action risk finding that the Russian insolvency administrator's unwinding claims have already consumed the assets they intended to reach — a scenario that Russian courts have shown they will countenance even where the Turkish creditor holds a prior contractual entitlement.

The 2026 development does not render recovery straightforward — it removes one significant doctrinal obstacle while introducing others. A creditor who proceeds without careful pre-litigation analysis of the specific structure in question risks challenging an intermediate entity that turns out to have sufficient economic substance to survive scrutiny, or pursuing a Russian claim that prejudices parallel enforcement in another jurisdiction.

The practical steps for Turkish creditors at this stage are as follows.

First, conduct a structured asset and corporate tracing review covering all entities between the Turkish creditor's claim and the Russian-located assets. This requires gathering corporate registry records, beneficial ownership data where available, and — critically — evidence of actual economic activity at each corporate level. The substance-over-form analysis adopted by Russian courts is only as useful as the evidence the creditor can place before the court.

Second, assess the insolvency risk of the Russian operating entity before committing to an enforcement strategy. If the Russian debtor is already technically insolvent or is likely to file within the relevant look-back period, the creditor's most effective route may be through the insolvency proceeding rather than independent enforcement — particularly given the administrator's augmented unwinding powers. See the firm's analysis at Unwinding shell company structures with Russian elements — practitioner briefing and the comparative analysis at Comparative analysis: unwinding shell company structures — jurisdictional approaches.

Third, consider whether any interim preservation measure is available in Russia or in a third jurisdiction that can freeze assets at the Russian operating level pending full proceedings. Russian courts can, in appropriate circumstances, grant interim relief in connection with pending claims — a step that becomes increasingly important as the 2026 practice developments make the doctrinal pathway clearer but the asset recovery timeline longer.

For Turkish creditors navigating this landscape, early instruction of Russian counsel with asset tracing and recovery experience is the precondition for any of these steps to be effective. The firm's Asset Tracing & Recovery practice handles cross-border mandates of this nature, with direct partner involvement from instruction through to enforcement. Matters involving related insolvency questions are handled in coordination with the firm's Restructuring & Insolvency team. For a record of representative engagements, see the firm's Matters page.

To discuss a recovery matter involving shell structures and Russian-held assets, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• Unwinding shell company structures with Russian elements — practitioner briefing
• Comparative analysis: unwinding shell company structures — jurisdictional approaches
• Asset tracing and recovery in Russia: options for foreign creditors

Q: What specifically changed in Russian courts' approach to unwinding shell structures in 2026?

A: Russian courts entering 2026 have adopted a more pronounced substance-over-form methodology when assessing intermediate holding entities. Where previously courts largely deferred to formal corporate registration and nominal commercial activity as evidence of genuine legal personality, appellate and cassation practice now applies a structured inquiry into whether the entity exercised genuine economic independence — its own management, commercial risk-bearing, and arm's length dealings with the underlying Russian operating company. Where that test is not met, courts have shown increasing willingness to treat the intermediate structure as transparent, enabling creditors to assert claims directly against the Russian-held assets beneath it. This shift does not make recovery automatic, but it removes a doctrinal barrier that previously frustrated well-founded creditor claims.

Q: Which Turkish creditors are most directly affected by the 2026 developments?

A: Three groups face the most immediate practical implications. Turkish trade creditors with overdue receivables from Russian counterparties — particularly in construction, textiles, agriculture, and manufacturing — who have encountered offshore or intermediate holding structures when attempting enforcement. Turkish investors or joint venture partners seeking to recover capital contributions or enforce contractual rights where the arrangement used an intermediate vehicle as the nominal Russian counterparty. And Turkish creditors involved in Russian insolvency proceedings, where the administrator's transaction-unwinding powers have been applied with greater confidence to transfers structured through intermediate shells. All three groups should treat the 2026 shift as an opening to reassess previously abandoned or deprioritised recovery positions.

Q: What practical steps should Turkish creditors take now?

A: Three steps have the greatest practical value at this stage. First, commission a structured asset and corporate tracing review to map all entities between the creditor's claim and the Russian-located assets — including gathering evidence of actual economic activity at each corporate level, since Russian courts now require substantive evidence, not merely structural diagrams. Second, assess the Russian debtor's insolvency risk before committing to a strategy, since the administrator's unwinding powers in an insolvency may operate in parallel with or in competition with the creditor's independent claim. Third, explore interim preservation measures — in Russia or in a third jurisdiction — to protect assets during the potentially extended timeline that enforcement through the new doctrinal pathway entails. Early instruction of Russian counsel is the prerequisite for all three steps.

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

The firm's Asset Tracing & Recovery practice advises foreign creditors — including Turkish trade creditors, institutional investors, and joint venture partners — on locating, preserving, and recovering assets held through Russian entities and intermediate offshore structures. Working closely with the firm's Restructuring & Insolvency team, the practice has handled cross-border recovery mandates across the Siberian, Ural, and Central federal districts, with direct partner involvement at every stage.

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 & Asset Protection, Vetrov & Partners vetrovpartners.com/razina/

When a foreign trade creditor attempts to enforce a judgment or arbitral award against a Russian state-related entity, it frequently encounters a corporate architecture that changed significantly after 2022 – a Cyprus intermediate holding company that once served as a straightforward enforcement target has, in many cases, been emptied, re-domiciled, or rendered structurally opaque. The legal framework governing these Cyprus-Russia corporate structures shifted in ways that material affect how creditors can trace assets in Russia, identify beneficial ownership, and pursue recovery. This update sets out what changed, who is most exposed, and what foreign creditors with live enforcement interests should do now.

The Russia-Cyprus relationship that underpinned decades of holding-structure planning rested on two pillars: a Double Tax Treaty providing reduced withholding rates, and a permissive Russian regulatory environment that broadly recognised Cyprus-registered entities as legitimate counterparties for domestic transactions, financing arrangements, and asset ownership. Both pillars weakened substantially after 2022.

Russia suspended the operative provisions of the Double Tax Treaty with Cyprus in August 2023 – a measure that followed analogous suspensions with other treaty partners in the same period. From a creditor's perspective, the immediate consequence was less about tax efficiency and more about structural incentive: the tax rationale for Cyprus holding chains diminished, which accelerated a broader repositioning of corporate structures by Russian groups that had previously relied on Cyprus vehicles. Many of those repositionings were not straightforward re-domiciliations – they involved asset transfers, novations of receivables, and intercompany loan restructurings that, in the hands of state-related counterparties, were conducted with considerable speed and limited transparency.

In parallel, Russian legislative and regulatory developments introduced several changes relevant to creditors tracing assets through Cyprus-Russia holding chains. Russian courts and tax authorities moved toward a more aggressive look-through approach – examining the economic substance behind a Cyprus entity rather than treating its formal legal ownership as determinative. This approach, which had been developing incrementally under Russian transfer-pricing and controlled-foreign-corporation rules, accelerated materially in the post-2022 period. The practical effect for a creditor is twofold: the same legal tools that allow the Federal Tax Service to look through a Cyprus holding structure to assess beneficial ownership of Russian income can, in principle, be deployed analytically by creditors seeking to identify which assets a state-related entity effectively controls through a Cyprus chain, even where formal legal title has been transferred.

The second material change is the treatment of Cyprus entities in enforcement proceedings. Under the approach that has developed in Russian arbitrazh courts in recent years, a Cyprus-registered company that was the formal counterparty to a contract or the registered shareholder in a Russian subsidiary is not automatically treated as the economically relevant party for enforcement purposes. Courts have shown increasing willingness to examine corporate substance – registered office only, no staff, no independent decision-making – as a relevant factor when creditors seek to pierce holding structures or when respondents seek to interpose a Cyprus vehicle as a shield against Russian-law claims.

The creditors most directly affected by the post-2022 shift in Cyprus-Russia corporate structures are those whose underlying claim or security arrangement involves a state-related Russian entity that formerly operated through a Cyprus intermediate. This category is broader than it may initially appear.

State-related entities in Russia encompass not only wholly state-owned enterprises but also entities in which a regional or municipal government holds a significant minority interest, entities controlled by state development banks or state-held funds, and entities operating under long-term public concession arrangements. A foreign creditor that extended trade credit or financing to what appeared to be a commercially operated Russian counterparty may find, on closer analysis, that the ultimate beneficial controller is a state-linked entity – and that the Cyprus holding vehicle through which that entity operated has been materially altered since 2022.

The exposure takes several forms. First, a creditor who holds security over shares in a Cyprus company that itself holds shares in a Russian operating entity may find that the Russian subsidiary has been stripped of operating assets, with business continuity transferred to a newly incorporated Russian vehicle outside the Cyprus chain. Second, a creditor who obtained an English or LCIA arbitral award against a Cyprus entity – expecting to enforce against Russian assets through the Cyprus vehicle – may find that the Cyprus entity no longer holds those assets and that enforcement in Russia against the Russian beneficiary requires a separate set of Russian-law proceedings that were not anticipated at the time of contracting.