On 4 August 2026, the President of the Russian Federation signed Federal Law No. 319-FZ, which inserts a new Article 20.1 into the Federal Law on Foreign Investments and allows a Russian court to cancel the buy-back option that many departing foreign investors took in place of a market price when they left Russia after February 2022. For the trade practitioner, the significance of the measure lies not in the exit terms it sits alongside, which already leave a seller with something near 5% of appraised value once the 60% discount and the 35% budget contribution are read together, but in its reach backwards into transactions that closed years ago and in the discretion it confers. Two features require close attention: the two-part test, which pairs a conduct provision drawn broadly enough to catch a public announcement of withdrawal with an economic one directed both at token-price exits and at businesses the acquirer has since recapitalised; and the compensation for the loss of the, the claim lies against the acquirer rather than the state, and the same court that cancels the option calculates the sum (or refuse it altogether). This alert examines the new article, the standing and venue rules that send every claim to a single Russian court, and how a judgment of this kind would fare against the EU’s new non-recognition rule and the investment-treaty position. Read the full analysis here.
