The registry is dated November 12, 2026. According to First Department, besides Leonid Parfenov and Boris Grebenshchikov, it includes journalists Yulia Latynina, Andrei Loshak, Maxim Kurnikov and Vera Krichevskaya, film critic Anton Dolin, director Vitaly Mansky, musicians Vera Musayelyan and Ligalize, rights activist Anastasia Burakova, and public figures Pavel Khodorkovsky and Tatyana Usmanova.
The formal basis for keeping the list is Article 7.4 of Law No. 115-FZ "On Countering the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism." The provision allows assets to be blocked when there are "sufficient grounds" to suspect a person of involvement in terrorism, extremism or sabotage. The law does not explain what counts as sufficient grounds.
The decision is made by the Interdepartmental Commission on Countering the Financing of Terrorism at Rosfinmonitoring, Russia's financial monitoring agency. The procedure is conducted in secret and outside the courts, after which the lists are sent to banks and financial institutions. According to First Department, the registry differs from the public list of "terrorists and extremists": the closed list includes those for whom no formal grounds were found for the public one.
Restrictions on those listed are practically the same as those applying to people on the open list. Accounts are frozen, and banking operations and real estate transactions in Russia are banned. Under the law, a person can claim only a monthly humanitarian allowance, paid out of their own blocked funds.
First Department lawyer Evgeny Smirnov said the criteria for inclusion in the registry do not exist and anyone deemed involved in "extremist" or "terrorist" activity can be added. According to him, being placed on the list may signal interest from security services and may precede the opening of a criminal case. At the same time, the commission's decision itself is not considered a charge or a court verdict.
Smirnov noted that the commission's decisions should be published, but it has no website of its own, and the information does not appear on Rosfinmonitoring's resources. The restrictions can be challenged in court, but assets remain frozen until proceedings begin, and the grounds for blocking may be unknown to the owner.
In late September, the prosecutors general of Russia, Belarus, Kazakhstan, Kyrgyzstan, Tajikistan and Uzbekistan signed an agreement on cooperation in combating terrorism and extremism, RBC reported. The document provides for the exchange of information on "terrorist and extremist organizations, groups and individuals who pose a threat to the security of states," including those not yet held accountable.
In July, gallery owner Marat Gelman said that under a similar out-of-court procedure the authorities had frozen the assets of about 100 people linked to the SlovoNovo festival and the Dar literary prize. The restrictions became a problem for 15–20 people who still had assets in Russia.