Whilst this has not been formally announced yet, we understand that the Sub-Commission of the Government Commission for Control over Foreign Investments in Russia, which is one of the ultimate decision-makers in counter-sanctions matters, has resolved, pursuant to the relevant instructions of the Russian President, that the conditions for clearing transactions whereby non-Russian companies associated with unfriendly states sell their Russian securities, including shares/equity interests in Russian companies, should be materially tightened.
Read in detail in the alert at the link:
https://www.stonebridgelegal.ru/media/files/Alert_Conditions_for_exit_tightened_October_ENG.pdf