Starting September 1, 2025, a new procedure for obtaining Federal Antimonopoly Service (FAS) clearance of transactions involving the acquisition of shares and assets of financial organizations will enter into force.

An amendment to Article 29 of the Federal Law “On Protection of Competition” (paragraph 1.1) introduces a requirement to obtain prior FAS approval not only in relation to the target company, but also in relation to the acquiring financial organization.

Thus, the list of cases where antimonopoly clearance is required is expanding.

New Threshold Values

FAS clearance will be required if the buyer’s assets exceed:

25 trillion rubles – for credit institutions;

300 billion rubles – for insurance organizations (except medical insurance companies);

180 billion rubles – for leasing companies;

2 billion rubles – for insurance brokers.

Liability for Non-Compliance

Entering into a transaction without prior FAS approval entails an administrative fine for the buyer ranging from 300,000 to 500,000 rubles (Part 3, Article 19.8 of the Code of Administrative Offenses).

On March 26, 2025, draft law No. 875355-8 was submitted to the State Duma, proposing to raise fines to 800,000–1,000,000 rubles. However, given that the state duty for reviewing such applications increased more than tenfold in 2024 (and now amounts to 400,000 rubles), it is possible that the final version of the bill will include even higher liability thresholds.

Source: Federal Law of December 28, 2024 No. 539-F