They explained which purchases under the Law N 223-FZ are not placed in the EIS, and recommended to advance contracts
Since the beginning of March, there has been a decree on the non-placement of information on certain purchases in the EIS, namely:
customers under sanctions and/or restrictions (including credit institutions);
credit institutions, if such measures have been introduced against the persons who control them.
The Ministry of Finance, among other things, clarified that in other cases these rules are not used. For example, when purchasing by a subsidiary, if the shares in its authorized capital belong to the customer under sanctions and this customer is not a credit institution.
There is no list of customers against whom restrictive measures have been established. Innovations are applied:
from the date of the imposition of sanctions against the customer. If such measures were established before the entry into force of innovations, then from March 7;
based on publicly available information.
It should be noted that the resolution on the non-placement of information in the EIS was adopted to smooth out the consequences of restrictive measures. For the same purpose, the Ministry of Finance recommends setting an advance of at least 50% of the NMCD at the conclusion of any contracts that are executed in 2022. In this case, customers must ensure control over the expenditure of funds.
Document: Letter of the Ministry of Finance of the Russian Federation dated 04/18/2022 N 24-01-09/34211