The distinction between types of corporate ownership  in  Russian law requires English readers to overcome what would seem an odd turn of phrase. 

A Russian limited liability company (Общество с ограниченной ответственностью, Obshchestvo s ogranichennoy otvetstvennostyu) may have one or more founders, who can be individuals or legal entities. These founders are referred to as “participants” (участники, or uchastniki), and they own “participation interests” (доли участия or just доли, dolyi uchastiya or dolyi) in the company’s charter capital. The size of a participant’s share corresponds to their contribution, which can take many forms: cash, securities, tangible assets, or intellectual property.

By contrast, a private joint stock company (Закрытое акционерное общество, Zakrytoe aktsionernoe obshchestvo) divides ownership via shares (акции, aktsiyi) among its shareholders (акционеры, aktsionery). Shares can be owned by individuals or other corporate entities, and shares are distributed, often through closed subscriptions, but are not publicly traded.

Finally, a public joint stock company (Публичное акционерное общество, Publichnoe aktsionernoe obshchestvo) has a similar structure, but with the added feature that its shares may be traded on stock exchanges. Shares can be owned by individuals, corporate entities, and frequently, the state itself, represented either directly through government stakes or indirectly via other public joint stock companies. Interestingly, limited liability companies are also permitted to acquire shares in joint stock companies.

The key distinction is simple yet crucial: in Russia, limited liability companies have participants (участники), while joint stock companies have shareholders (акционеры). Translators must remain vigilant to these differences, particularly when the organizational context requires precise vocabulary choices.

In a recent case, a charter for a limited liability company required careful translation of участник as “participant,” reflecting both the company form and the legal terminology in use. However, the document also referred to ownership by the limited liability company of shares in joint stock companies: here the term акционер, “shareholder”, was used. Recognizing the different legal structures – and faithfully representing these distinctions in English – was essential to producing an accurate translation.