Since May 3, 2022, all Russian organizations, including customers under laws No. 44-FZ and 223-FZ, are prohibited from entering into transactions with companies and individuals who are under Russian sanctions, and with persons controlled by them. In addition, with the listed participants, it is impossible to:
execute transactions that were concluded but not executed before May 3, 2022;
conduct financial transactions;
to export goods and raw materials for them.
The Government has approved a list of specific persons with whom it is prohibited to conclude and execute transactions. The parameters of the transactions were specified (Resolution No. 851 of 11.05.2022).
Customers under 44-FZ and 223-FZ must include in the notification or documentation a new requirement for procurement participants. The following wording can be used: "The procurement participant must not be a legal entity or an individual against whom special economic measures provided for in subparagraph "a" of paragraph 2 of Decree of the President of the Russian Federation No. 252 of 03.05.2022 "On the application of retaliatory special economic measures in connection with the unfriendly actions of some foreign States and international organizations", or be an organization under the control of such persons."
Document: Presidential Decree No. 252 dated 03.05.2022
Government Resolution No. 851 of 11.05.2022