Compensation from broker for Russian CFD (contract for difference)

The UK Financial Ombudsman has ordered Interactive Brokers (IB) to compensate an investor that invested in a Russian CFD (contract for difference). In this case the CFD was for 10.000 Sberbank ordinary shares. Interactive Brokers refused to close the position because they could not trade the underlying Sberbank shares Interactive Brokers had bought to cover the CFD contract. From March 2022 onwards, IB raised the margin required for the position to 100%. By August 2024 the interest alone charged on the position had amounted to around USD $12,000.  The European Securities and Markets Authority (ESMA) introduced a margin close-out rule in 2018 that states that CFD providers have to close positions once the net asset value in the investor's account drops to 50% of the required margin. The Financial Ombudsman ruled that Interactive Brokers was required to stop charging interest and other charges on the CFD position once they had to close the position on the basis of the ESMA 50% margin...

Current situation regarding the payments of dividends - dividends on ADR's are again being paid

We receive a fair amount of questions regarding the payment of dividends. In this post we aim to describe the current situation as the regulations have changed over the years.

Dividend payments on ADR's are again possible 
At the end of November 2025 the regulatory framework regarding the payment of dividends on ADR's was significantly changed. In the past no dividends were paid on ADRs unless the Russian issuer had received permission to extend their depositary receipt program. Various companies, such as Novatek, were granted such permissions, but no dividends were paid on the majority of Russian ADR's.

On November 28, 2025, Federal Law No. 431-FZ entered into force. Articles 6 and 7 of this law removed the restriction for dividend payments on shares underlying depositary receipts. New dividends can therefore be paid on depositary receipts (ADR's)!

In addition, Article 16 of the law, changed the period for claiming previously unpaid dividends. Unpaid dividends can now be claimed for at least 3 years after conversion of the depositary receipts into ordinary shares. This extended deadline for claiming missed dividends unfortunately does not apply to those dividends that could no longer be claimed because the (normally 3 year) period for claiming missed dividends had already expired before the entry into force of the new legislation. Some issuers, such as Rosneft, extended the 3 year period to 5 years and their dividends that were declared in 2022 have not yet been added to their retained earnings and can therefore be claimed for many years after the conversion of depositary receipts into ordinary shares.

Dividends are forcibly paid to your custodian if you do not claim them yourself during 'the first stage of claiming dividends'
Investors could previously claim missed dividends themselves in various stages if the broker did not provide the information required for the payment of dividends. The easiest and first stage was claiming the dividends via the relevant Russian custodian of the foreign nominee holder (your Western brokerage firm; for example Raiffeisenbank Russia for Interactive Brokers). The first stage lasts a couple of months. The second stage was claiming the missed dividends via the Russian issuer directly. On the 28th of August 2024 the Central Bank of Russia changed the framework for the payment of dividends and the changes have been maintained ever since, and also in the latest version of the 26th of December 2025. 

Since the end of August 2024 the following applies: If the western nominee holder or the individual investor does not provide the required information about the individual investor during the first stage, the dividends will not be transferred to the personal account of the individual investor but will instead be transferred into the type C account that is opened in the name of the Western nominee holder. It is no longer possible for the individual investor to then claim these dividends via the issuer directly at a later stage once the first stage has passed. Although the advantage is that the dividends are not lost if the investor fails to claim them within 3 years, investors that want to have the dividends paid in their own personal account should now act in the first stage and apply for payment to the Russian custodian of their nominee holder.