Change of approach to the bonus payments to employees
As of September 1, 2025, amendments[1] to Article 135 of the Labor Code of the Russian Federation have entered into force, reaffirming the Constitutional Court’s position that prohibits the arbitrary deprivation of employees’ bonuses. Employers are now required to establish a transparent and documented bonus system that clearly defines the types, amounts, timing, and conditions of payments, and to ensure that employees are familiarized with these rules against their signature.
The amendments explicitly prohibit the complete deprivation of a bonus that forms part of an employee’s salary. A reduction may only be applied in the month in which a disciplinary sanction is imposed and may not exceed 20% of the employee’s total monthly earnings. Non-compliance with these requirements entails administrative liability — a warning or a fine of up to 50,000 rubles for organizations.
Employers are advised to review and update their internal bonus policies and employment documentation to ensure full compliance with the new rules.
[1] Federal Law No. 23-FZ "On Amendments to the Federal Law "On Personal Data" and Certain Legislative Acts of the Russian Federation"
Russian Court Grants Interim Relief in Support of International Arbitration in London
In August 2025, a Russian court of general jurisdiction granted interim relief in support of an arbitration proceeding administered by the London Court of International Arbitration (LCIA)[2]. The court imposed an asset freeze against the respondent pending the arbitral tribunal’s award and, in doing so, effectively recognized a non-signatory as a party to the arbitration agreement. This ruling is particularly significant in shaping case law at a time when cooperation with arbitral institutions in “unfriendly” jurisdictions has become increasingly restricted.
This precedent confirms that Russian courts remain willing to employ procedural instruments to safeguard claimants’ proprietary interests even in cross-border disputes. At the same time, the ruling raises important questions regarding jurisdiction, exequatur, and the relationship between claims filed before national courts and those submitted to international arbitration.
[2] Ruling of the Zamoskvoretsky District Court of Moscow, 23 March 2025, case No. 13-1256/2025
Presidential Decree No. 436: New Rules for Foreign Investors
On 1 July 2025, the President of the Russian Federation signed Decree No. 436 “On Additional Guarantees of the Rights of Foreign Investors” (“Decree 436”). According to the adopted document, starting from July 2025, foreign investors are entitled to make investments in the territory of the Russian Federation without being subject to certain provisions of the temporary economic measures that had been introduced.
The Decree expands opportunities for participation of foreign investors — including those from “unfriendly” jurisdictions — by allowing them to acquire Russian assets without prior approval from regulatory authorities.
Still, the additional guarantees of foreign investors’ rights that have been established apply to a limited list of transactions, in particular:
·acquisition of issued securities during their initial placement (IPO) or on the organized market based on a public offer;
·disposal of such securities in organized trading under a public offer;
·receipt of income (dividends, coupon payments) on such securities;
·placement of funds on deposits with Russian banks and fulfillment of deposit repayment obligations;
·entering into derivative transactions on organized markets based on a public offer and settlement of obligations under such transactions.
The Decree establishes a special procedure for carrying out such operations, namely, all relevant settlements and transactions by foreign investors must be conducted exclusively through special “In” accounts, while the use of any other accounts, such as standard current accounts, for these purposes is not permitted.
The significance of Decree No. 436 lies in the fact that, for the first time since the adoption of a series of counter-sanctions decrees by the President of the Russian Federation, it introduces a rather permissive regime for foreign persons, which may indicate the beginning of a gradual adjustment of the previously imposed restrictions.
Nevertheless, it should be noted that these relaxations apply only to a limited number of transactions/operations. In addition, the practical implementation of this mechanism is still in progress: banks are currently working on the technical rollout of functionality for opening and servicing “In” accounts.
As of September 1, 2025, amendments[1] to Article 135 of the Labor Code of the Russian Federation have entered into force, reaffirming the Constitutional Court’s position that prohibits the arbitrary deprivation of employees’ bonuses. Employers are now required to establish a transparent and documented bonus system that clearly defines the types, amounts, timing, and conditions of payments, and to ensure that employees are familiarized with these rules against their signature.
The amendments explicitly prohibit the complete deprivation of a bonus that forms part of an employee’s salary. A reduction may only be applied in the month in which a disciplinary sanction is imposed and may not exceed 20% of the employee’s total monthly earnings. Non-compliance with these requirements entails administrative liability — a warning or a fine of up to 50,000 rubles for organizations.
Employers are advised to review and update their internal bonus policies and employment documentation to ensure full compliance with the new rules.
[1] Federal Law No. 23-FZ "On Amendments to the Federal Law "On Personal Data" and Certain Legislative Acts of the Russian Federation"
Russian Court Grants Interim Relief in Support of International Arbitration in London
In August 2025, a Russian court of general jurisdiction granted interim relief in support of an arbitration proceeding administered by the London Court of International Arbitration (LCIA)[2]. The court imposed an asset freeze against the respondent pending the arbitral tribunal’s award and, in doing so, effectively recognized a non-signatory as a party to the arbitration agreement. This ruling is particularly significant in shaping case law at a time when cooperation with arbitral institutions in “unfriendly” jurisdictions has become increasingly restricted.
This precedent confirms that Russian courts remain willing to employ procedural instruments to safeguard claimants’ proprietary interests even in cross-border disputes. At the same time, the ruling raises important questions regarding jurisdiction, exequatur, and the relationship between claims filed before national courts and those submitted to international arbitration.
[2] Ruling of the Zamoskvoretsky District Court of Moscow, 23 March 2025, case No. 13-1256/2025
Presidential Decree No. 436: New Rules for Foreign Investors
On 1 July 2025, the President of the Russian Federation signed Decree No. 436 “On Additional Guarantees of the Rights of Foreign Investors” (“Decree 436”). According to the adopted document, starting from July 2025, foreign investors are entitled to make investments in the territory of the Russian Federation without being subject to certain provisions of the temporary economic measures that had been introduced.
The Decree expands opportunities for participation of foreign investors — including those from “unfriendly” jurisdictions — by allowing them to acquire Russian assets without prior approval from regulatory authorities.
Still, the additional guarantees of foreign investors’ rights that have been established apply to a limited list of transactions, in particular:
·acquisition of issued securities during their initial placement (IPO) or on the organized market based on a public offer;
·disposal of such securities in organized trading under a public offer;
·receipt of income (dividends, coupon payments) on such securities;
·placement of funds on deposits with Russian banks and fulfillment of deposit repayment obligations;
·entering into derivative transactions on organized markets based on a public offer and settlement of obligations under such transactions.
The Decree establishes a special procedure for carrying out such operations, namely, all relevant settlements and transactions by foreign investors must be conducted exclusively through special “In” accounts, while the use of any other accounts, such as standard current accounts, for these purposes is not permitted.
The significance of Decree No. 436 lies in the fact that, for the first time since the adoption of a series of counter-sanctions decrees by the President of the Russian Federation, it introduces a rather permissive regime for foreign persons, which may indicate the beginning of a gradual adjustment of the previously imposed restrictions.
Nevertheless, it should be noted that these relaxations apply only to a limited number of transactions/operations. In addition, the practical implementation of this mechanism is still in progress: banks are currently working on the technical rollout of functionality for opening and servicing “In” accounts.