Dividend payments on Russian ADRs

Earlier this year we wrote about the change in legislation that removed the ban on dividend payments on Russian ADRs: https://news.eahciss.org/2026/01/current-situation-regarding-payments-of.html?m=1.

We have now been receiving confirmations from the Russian custodian banks that hold the ordinary shares underlying the ADRs that they are now again receiving dividends on the shares underlying the ADRs. However, one custodian bank also implied that it depended on whether the issuer had fully implemented the change in legislation yet. So some issuers may not have updated their payment process.

Custodian banks only display the ISIN for the ordinary shares underlying the ADRs in their information sheets with application deadlines for payment in your own bank account. So investors are advised to first determine the ISINs of the shares underlying the ADRs they hold, before checking the application deadlines.

If no individual application is made before the deadline, then the dividends on shares underlying ADRs will be paid into a type C account in the name of the US depository banks that manage the ADR programs. JPMorgan recently confirmed that they received dividends on Rosneft ADRs in their type C account.

It may be especially interesting for investors from countries that did not introduce restrictive measures against the Russian Federation to claim these dividends on ADRs as that enables reinvestment of dividends.

Russian lawyer Irina Sibirina from www.itlektis.ru is preparing to claim Lukoil dividends on ADRs via RenCapBank. Investors that would be interested in this can contact her. She is currently on holiday, but will be back in the beginning of September.

EAHCISS is also engaged in an attempt to set up a test case for claiming missed dividends on Rosneft ADRs that were not paid to JPMorgan. Rosneft differs from other ADRe programs, because Rosneft received permission from the Russian government committee to continue the ADRs program and was therefore allowed to continue dividend payments on ADRs.