Foreign-to-foreign transactions with the Russian element may require special regulatory approval of the Russian agencies (similar to US CFIUS) along with the merger control filing. A separate filing can be required if within scope of a transaction falls a Russian entity engaged in activities of strategic importance for national defense and state security, as well as if a purchaser is controlled by the foreign state or international organization. The article highlights regulatory issues related to separate filings under the Strategic Investments Law and the Foreign Investments Law. Awareness can help foreign investors to avoid significant liability, making the non-compliant transaction null and void.
