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"Friendly" shareholders of Cypriot Rusagro ADR's can apply for direct ownership in the Russian Rusagro entity until the end of 2026

For various Russian companies the shareholder rights of the western holding company were suspended under the ESO-law (ESO is an acronym for Economically Significant Organization; the relevant law is Federal Law No. 470-FZ of 04.08.2023 "On the Specifics of Regulation of Corporate Relations in Business Entities That Are Economically Significant Organizations"). Normally shareholders in the western holding then have a 3 to 4 month period to apply to receive shares in the Russian entity. For Rusagro this period ended on the 28th of December 2024. In July 2025 new amendments to Federal Law No. 470-FZ were adopted. The newly introduced parts 20-22 of article 7 now allows for Russians and investors from jurisdictions friendly to Russia to apply for shares in the Economically Significant Organization until the end of the suspension of corporate rights of the western holding company. This is mandatory for Russians. Rusagro requested the Moscow court to extend this period until the 31...

Voluntary conversion of Okey group ADRs

We can now confirm that it is possible to successfully convert Okey group ADRs bought on the AIX into the underlying ordinary shares via voluntary conversion. Okey group, which is the owner of the "Da!" discount supermarkets in Russia, is planning to undergo redomiciliation from Luxembourg to Russia.  The ADRs of the Okey group are traded on the Moscow exchange (39.24 Rubles at the time of writing, which is about 0.50 USD) and on the Astana International Exchange (AIX) (current share price 0.30 USD). The ADRs are also traded over-the-counter (OTC).  After conversion of the ADRs you will receive a share certificate and you will be entered into the shareholder register in Luxembourg as a direct shareholder. Upon redomiciliation of Okey group to Russia your ordinary shares will be automatically transferred to the Russian shareholder register.  In our test run the process took various months to complete, but new cases may be quicker now that the process has been tested. Pleas...

Compensation from brokers for failed ADR conversion

Many investors did not manage to successfully convert their Russian ADRs because their western broker was too slow to process the request.  We are now seeing the first cases where arbitration committee's are compensating investors for these failures. We are aware of cases that were settled in the Netherlands where the broker compensated the full purchase price of the ADRs in addition to continued ownership of the ADRs as compensation for a failure to timely process a request for conversion of the ADRs into undelying Russian shares. There are also cases in the UK where the Financial Ombudsman ordered compensation for a failure by Interactive Brokers to process the request for conversion of Gazprom ADRs timely (see https://www.financial-ombudsman.org.uk/decision/DRN-5538810.pdf). We feel that the compensation rewarded could have been much higher if the investor would have presented the facts more fully (such as the statutory period of 3 years to claim unpaid dividends). Earlier the D...

What happens to Russian ADR's?

We are often asked what will happen to unconverted ADR's. The honest answer is: we don't know. We do know that the ADR programs have expired for most issuers and that this allows the depositary banks (BNY, JPMorgan, Deutsche Bank, Citibank and RCS issuer) to sell the shares that are underlying the ADR's and distribute the cash received (after costs are subtracted). There is a concrete example of this. JPMorgan participated in the tender offer that was launched by Magnit supermarkets ( https://www.magnit.com/en/shareholders-and-investors/project/ ). Part of the tender offer was a 50% discount compared to the average share price on the Moscow stock exchange over a 6 month period. Permission would normally be required from the Russian government for such a sale. The current discount that the Russian government committee applies is 60% ( https://minfin.gov.ru/ru/permission/79-81?id_57=309307-vypiska_iz_protokola_zasedaniya_podkomissii_pravitelstvennoi_komissii_po_kontrolyu_...

Update on Cifra's fees - fees have been lowered

We earlier reported on the fees Cifra started charging for holding securities in type C accounts. This led to many parties raising the issue of high fees with Cifra broker. Various investors already noticed that the 0.25% monthly fee was not applied by Cifra in January 2026. Cifra published the new fee schedule on its website yesterday. In the new fee schedule the 0.25% monthly fee for holding securities via type C accounts via NSD has been amended to a monthly fee of 0,0015%. The new lower fee is applied retroactively from the 1st of January 2026. The new fee schedule can be found here: https://cifra-broker.ru/about/company/news/ooo-tsifra-broker-obnovilo-reglamentiruyushchie-obsluzhivanie-klientov-dokumenty-57362/

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 m...

Possible exchange of Russian non-Ruble bonds in Ruble bonds

Article 6 of the recently adopted Federal Law No. 514-FZ of December 28, 2025 "On Amendments to the Federal Law "On Limited Liability Companies" and Certain Legislative Acts of the Russian Federation" allows Russian issuers to exchange, until the end of 2026, bonds issued in currencies of countries that are considered unfriendly under Russian law to bonds in Rubles. The exchange will take place at the official exchange rate set by the Central Bank of Russia on the day of the decision to exchange the bonds. Other aspects of the bonds, such as maturity dates, will remain the same. The legislation can be accessed here: http://actual.pravo.gov.ru/content/content.html#pnum=0001202512280026