Russia has imposed new barriers to foreign directed investment.
It used to be possible to appoint a foreign legal entity – e.g. a management company - as the Russian company’s General Director, however in practice that possibility has vanished. A newly appointed foreign director is required to a be a natural person, who will be subjected to the same civil and penal measures as his or her Russian counterpart; the protection of a foreign legal entity in between has thereby disappeared. Additional barrier is the mandatory application and obtainment of a Russian work permit for each foreign (individual) director.
An OOO – Limited Liability Company or LLC – can still have foreign shareholders; an additional condition to shareholding applies, when the LLC has only one (foreign) legal entity as shareholder. In such case the (foreign) shareholder itself needs to have at least two shareholders.