Claiming dividends on ADRs: Lukoil and Rosneft examples

In an earlier post we explained that ADR holders are currently again eligible to receive dividends payments on ADRs. Since our post various other organisations wrote articles about this topic, and many of our members also received this week's Lawflash from Morgan Lewis (https://www.morganlewis.com/pubs/2026/01/update-russia-introduces-new-rules-for-dividend-payments-on-depositary-receipts).

Because of the questions that we continue to receive about this topic we would like to take the recent dividend payments by Lukoil and Rosneft as an example.

Due to the complexity of the procedure it is generally recommended to claim these dividends with help from a Russian representative. EAHCISS can refer you to representatives that we have good experiences with.

If you successfully claim these dividends and are from a country that is considered unfriendly to Russia then the dividends will be paid into a type C account.

Lukoil example 

The record date for Lukoil dividends over the first nine months of 2025 was the 12th of January 2026. The ADR program for Lukoil is managed by Citibank North America. The Russian custodian bank for the Russian ordinary shares underlying the Lukoil ADRs is Citibank Russia. Therefore investors that hold ADRs in Lukoil outside of Russian infrastructure can now, for a temporary period of a couple of months, request payment of dividends into their own personal account via Citibank Russia. More information about the procedure can be found on the website of Citibank Russia: https://www.citibank.ru/corporate/securities_services/

Any remaining dividends that have not been subject to a timely request for payment into the personal account of the investor will be locked in the type C account opened in the name of Citibank North America. Citibank North America may distribute these dividends once sanctions and counter sanctions (type C regime) have been lifted. 

Rosneft example 

The record date for Rosneft dividends over the first nine months of 2025 was the 12th of January 2026. The ADR program for Lukoil is managed by JPMorgan Chase. The Russian custodian bank for the Russian ordinary shares underlying the Rosneft ADRs is Raiffeisenbank Russia. Therefore investors that hold ADRs in Rosneft outside of Russian infrastructure can now, for a temporary period of a couple of months, request payment of dividends into their own personal account via Raiffeisenbank Russia. More information about the procedure can be found on the website of Raiffeisenbank Russia: https://www.raiffeisen.ru/corporate/depositary/securities/

Any remaining dividends that have not been subject to a timely request for payment into the personal account of the investor will be locked in the type C account opened in the name of JPMorgan Chase. JPMorgan Chase may distribute these dividends once sanctions and counter sanctions (type C regime) have been lifted.