On December 28, 2015 President Putin issued new Decree No. 669 ("Decree No. 669") supplementing the foreign trade sanctions against Turkey that were imposed earlier by Presidential Decree No. 583, dated November 28, 2015. Pursuant to Decree No. 669, provision of certain services and performance of certain work by Russian legal entities should be prohibited or restricted, if such legal entities are controlled by Turkish persons.

For the purposes of the above, control should be determined in accordance with general criteria established by Russian Federal Law No. 57-FZ, dated April 29, 2008, On Foreign Investments in Russia.

The types of work and services falling under the restrictions and prohibitions are those generally listed by Russian Governmental Decree No. 1457, dated December 29, 2015 (Decree No. 1457), and they includes the following:

  1. Construction of buildings, engineering installations and specialized construction works;
  2. Activity in the sphere of architecture, design and engineering; technical tests, research and analysis;
  3. Activity of touristic agencies and other organizations providing services in the touristic sphere;
  4. Hotel business and other places for temporary accommodation;
  5. Provision of work and services for state and municipal needs;
  6. Processing of wood.

The list also includes special classifications of relevant work and service types.

At the same time, Decree No. 669 provides that certain contracts, to be defined and listed by the Russian Government, otherwise falling under the sanctions, may enjoy an exemption from the above measures.