Putin expanded the list of "unfriendly" persons: who will be affected by decree No. 816
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    Putin expanded the list of "unfriendly" persons: who will be affected by decree No. 816

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    —Putin expanded the list of "unfriendly" persons: who will be affected by decree No. 816
    13.11.2026
    New criteria for identifying persons from unfriendly countries will affect payments on securities and the procedure for fulfilling obligations to creditors

    On November 5, 2026, Russian President Vladimir Putin signed Decree No. 816, which amends a number of anti-crisis regulations. The document clarifies the categories of individuals equated with representatives of unfriendly states and introduces additional financial restrictions for them.

    Who falls under the new criteria

    According to the decree, persons from unfriendly countries now include individuals who have failed to provide one of the following documents:
    • a Russian citizen's passport,
    • a passport of a state that does not commit unfriendly actions,
    • a residence permit in Russia or a document confirming the right to permanent residence in a friendly jurisdiction.
    Thus, the absence of documentary confirmation of a connection with Russia or a friendly state becomes grounds for applying special economic measures.

    Which decrees have been amended

    Amendments have been made to six previously issued documents regulating the financial and corporate spheres. These include Decrees No. 81 (on financial stability), No. 95 (on obligations to foreign creditors), No. 254 (on corporate obligations), No. 618 and No. 737 (on the special procedure for transactions), as well as No. 198 (on payments on securities).

    Ban on payments on securities

    A separate provision of Decree No. 816 establishes that the specified individuals are not to receive payments on securities in accordance with paragraph 5 of Decree No. 198 of March 19, 2024. In addition, the fulfillment of obligations to such persons must be carried out in compliance with a special procedure, including through type "C" accounts.

    Frequently asked questions:

    1. Which decree did Putin sign on November 5, 2026?
      Decree No. 816 "On Amending Certain Decrees of the President of the Russian Federation."

    2. Who is now classified as an "unfriendly" individual?
      Individuals who have not presented a Russian passport, a passport of a friendly country, a residence permit in Russia, or a document confirming the right to reside in a friendly state.

    3. Which specific decrees have been amended?
      Decrees No. 81, No. 95, No. 254, No. 618, No. 737 and No. 198.

    4. What changes for payments on securities?
      Persons falling under the new criteria will no longer receive payments on securities pursuant to paragraph 5 of Decree No. 198.

    5. Does the decree apply to Russian citizens without a passport?
      Yes, formally the absence of a confirming document may lead to restrictions being applied, even if actual citizenship is Russian.

    6. How will the new decree affect the fulfillment of credit obligations?
      Obligations to such individuals will need to be fulfilled in a special procedure, for example, through type "C" accounts, as is the case with other unfriendly creditors.

    7. From what moment does the decree enter into force?
      From the day of official publication — November 5, 2026.

    8. Does the decree affect ordinary household transactions with individuals?
      No, it concerns only operations falling under specific anti-sanctions decrees (transactions with real estate, securities, loans, etc.).


    Photo source: https://www.magnific.com/

    For more information, please contact the consultants of the Confidence Group company.

    * The texts of the newsletters are intellectual property of Confidence Group, protected by the copyright laws of Russia. The information may not be reproduced in any form whatsoever without linking to this web site or to pages of this website.

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