The Russian government has issued Decree No. 844, establishing a framework for release of blocked shares held by foreigners in Russia and their exchange for assets of Russian investors blocked abroad. Foreign investors can use the procedure to buy blocked foreign securities held by Russian investors, using as consideration the cash held by foreigners on the frozen Type C accounts in Russia. European Union clearing systems effectively blocked the relevant foreign securities in June 2022 following the imposition of sanctions. The voluntary process will initially target small Russian assets blocked abroad, for which it will be the only way that foreign investors can use their frozen funds in Type C bank accounts without obtaining official approval.
News Source：【Morgan Lewis 2023/11/10】