On 1 July 2011, the Federal Antimonopoly Service (the "FAS") issued a letter on shareholders' agreements. According to the letter, the antimonopoly bodies also have the authority to approve the conclusion of shareholders' agreements under certain circumstances, for example, when one shareholder is granted the right to dispose of the shares of other shareholders.

The position of the FAS comes as no surprise to the players on the Russian financial market, as the antimonopoly body has been moving steadily in the direction of requiring this type of approval.

[Letter of the Federal Antimonopoly Service "A shareholders' agreement granting one party the right to vote as per another party's shares is subject to approval of the antimonopoly body", dated 1 July 2011]