On November 23, 2018 the Russian Government issued Decrees No. 1403, No. 1404, No. 1405 (“Decrees“), establishing the right of Russian banks and credit institutions that fall under foreign sanctions to not disclose certain information that is normally subject to mandatory disclosure requirements.

In particular, the Decrees prescribe such banks and credit institutions to provide information on its shareholders and UBOs only to the Central Bank of Russia and to give motivated explanations. The Central Bank of Russia is recommended to not disclose such information publicly.

According to the Russian Government, the above measures are intended to safeguard the interests of Russian banks and credit institutions that fall under sanctions imposed by foreign states.

The Decrees are expected to come into force on December 5, 2018.