On 31 March 2022, Russia issued Decree No. 172, titled “On special procedure for the fulfilment of obligations by foreign buyers to Russian Natural Gas suppliers” (the “Decree”), under which gas supplied by Russian exporters after 1 April 2022 to “unfriendly” states was requested to be paid by way of a multi-step mechanism through specialised Gazprombank accounts − regardless of the actual contractual terms. The rationale behind the Decree was purportedly to strengthen the value of the rouble, which had weakened dramatically following the onset of the Russia-Ukraine conflict in February.
