Four years ago, the debate about the legal system framing E&P activities was centered on production-sharing agreement (PSA) laws. Some leading voices, including jailed Yukos chairman Mikhail Khodorkhovsky, deemed the law detrimental to the nation's interests and too favorable to foreign companies. The law was scrapped, triggering the ire of foreign investors, and only the agreements signed between the state and the foreign majors involved in the Sakhalin 1 and 2 and Kharyaga projects were "grandfathered." Today, there are rumors of the possible revival of PSA legislation to facilitate the development of the next generation of mega-projects on the Arctic shelf and elsewhere, but the focus of the industry is elsewhere. Everyone is waiting on the forthcoming new subsoil law, which is expected to come into force by the end of the year to replace one deemed out of date and ill-adapted by the industry. Drafts of the law have been circulated, dispositions have been leaked and some of its provisional content has caused alarm among the international oil and gas community, as well as among many of its Russian counterparts. The announced intention to limit access to underground mineral wealth considered "strategic" (affecting many industries beyond hydrocarbon extraction) without a clear definition of what that term encompasses, sends shivers down the spines of many executives from the nickel, gold, diamond and, most importantly, the oil and gas sector. Failing to clarify this point, Russia will send the wrong signals to the global oil and gas sector at a time when cooperation is required to develop the next generation of mega-projects. Meanwhile, other dispositions of the draft law, notably one calling for restrictions of access to foreign capital, with the necessity for companies involved in mineral extraction to be 50% Russian, added a great deal of confusion to an already worrisome situation. Other areas of uncertainty also appear, regarding the use of a double or of a simple key approach, i.e. giving authority over the licensing processes to both the federal government and regional institutions. Today's mineral law is based on a double-key approach, and regions have been wary of announced changes, which might reduce their considerable leeway on mineral extraction activities as well as financial returns. Yet, the draft law also contains dispositions that have been hailed as progressive by most. Rights of minerals development by a company that has conducted geological exploration work will certainly reassure most of the oil and gas industry and ease investments into difficult assets. It should also increase the number of greenfield exploration wells that have fallen to an all-time low in the past two years. The easing of license-transfer procedures should also provide the industry with more flexibility and should in turn boost activity, providing further incentives to foreign operators to seek opportunities. Beyond the subsoil law, which should durably reshape the sector in the years ahead, there is much work to be done to strengthen the Russian legal system and ensure that the courts are independent and fair, and are being given the means to render justice efficiently and with consistency. The regional courts notably need to see their work facilitated for the rule of the law to be strengthened. There are plenty of legal challenges to be addressed by the Russian Federation, and these are testing times. Andrey Goltsblat, senior partner at Pepeliaev, Goltsblat & Partners, a Moscow practice very involved in the industry, says, "In recent years, Russia has been hesitating between different courses of action, different directions. Today, its course seems defined but it needs to mark it out more clearly for the outside world, to stop misreading and misunderstanding its true intentions and take Russia seriously." The future subsoil law provides Russia with just such an opportunity to set the record straight and eliminate its old nationalistic and protectionist demons once and for all. The debate raging around this new law should be an honest, cooperative multilateral and constructive one. It is the right time in the country's recent history to proclaim its intention to be a genuine partner, open and friendly, looking at making the best use of its subterranean wealth, for the sake of its future.