Dividends on Rosneft depositary receipts - payment by JPMorgan and opportunity to claim dividends

EAHCISS earlier announced that JPMorgan liquidated the shares underlying the Rosneft depositary receipts (GDR's): https://news.eahciss.org/2026/07/jp-morgan-liquidated-shares-underlying.html?m=1

JPMorgan confirmed in the notification that they received dividends on the shares underlying the GDR's since 2025 (see https://api.markitdigital.com/jpmadr-public/v1/cms/document?cmsId=88b769796a7f408d9386afac6a01fd3f&sequenceNo=7):

"In February 2025, July 2025, January 2026 and July 2026, J.P. Morgan received dividends on the Rosneft Ordinary Shares underlying the outstanding DRs. However, distribution of dividends is not currently permitted under Russian regulations, which require these funds to be held in a restricted "type S" account in Russia. At such time that J.P. Morgan is permitted to do so, it will distribute such dividends pro rata among the Remaining DR Holders. J.P. Morgan cannot provide any assurance that any such additional distributions will be permitted under applicable laws and regulations, or operationally feasible."

Unlike Sberbank, Rosneft received permission in May 2022 from the Russian government committee to continue its GDR program. This permission allowed for the continued payment of dividends on GDR's.

At first these dividends were only paid to GDR holders that actively applied for these dividends and for holders for which JPMorgan supplied all the required information to Raiffeisenbank. Then, in August 2024, the Russian Central Bank amended its decision on the procedure for the payment of dividends (see https://www.cbr.ru/rbr/dir_decisions/rsd_2024-08-28_34_03/). This change resulted in dividends being forcefully paid to the nominee holder, and in the case of Rosneft GDR's to a type C account in the name of JPMorgan.

Unpaid dividends over 2021, 2022 and 2023 can be claimed directly by ADR holders with Rosneft. For a complete overview of distributed dividends see: https://www.rosneft.com/Investors/Dividends/

The normal 3 year statutory period for the payment of unpaid dividends does not apply because Rosneft extended this period in its Charter (https://www.rosneft.com/upload/site2/document_file/Rosneft_Charter.pdf) to 5 years:

"7.8. Any persons failing to receive a declared dividend because the Company or the registrar lacks accurate and necessary address details or banking details or for reason of any other delay on the creditor’s part may file a claim for payment of such dividends (unclaimed dividends) over a five-year period from the date to be determined in accordance with the legislation of the Russian Federation."

Given the complexity of the procedure to claim unpaid dividends, and the need to work with local Russian notaries and translators, we strongly advise to consider working with a local Russian representative and to start preparations as soon as possible. EAHCISS has good previous experiences with Irina Sibirina from www.itlektis.ru and Magenta Legal (www.magenta.legal). Both are also members of EAHCISS.