The Central Bank of Russia has issued an ordinance, now registered by the Russian Ministry of Justice, requiring non-governmental pension funds (NPFs) to identify and manage conflicts of interest. NPFs may permit conflicts only where customers have been informed and customers’ rights are not violated. The ordinance sets out rules for detecting conflicts and lists situations that may create them, including an NPF acquiring securities of an affiliated company or entering into a transaction with a related party. NPFs must also keep records of information on conflicts of interest; the requirements are aligned with the approaches used for professional securities market participants and management companies. The ordinance enters into force on 21 February 2025.