EAHCISS News (English)

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 share...

We sent out the annual invoices to all members of EAHCISS today. You should be able to find the invoice in your e-mail inbox and in the online membership portal. We are aware that emails may sometimes end up in spam folders. Please do not hesitate to contact us at contact@eahciss.org if you did not receive an invoice or have any other issues or questions. Please contact us if you prefer to pay in USD and we will share our USD account details.

Earlier we asked for help to complete a survey. We can now share the results. We thank all investors that completed the survey. The raw data can be accessed here: https://docs.google.com/spreadsheets/d/1cxPFLwAuFP9hTeBWtWAC35GtuFztWdUM-PyNIhyY4Yw/edit?usp=drivesdk Our understanding is that many brokers have reconciliation problems where the number of ADRs administered does not match the number the custodian has in their books. In our opinion (EU) sanctions do not warrant the freezing of the funds. We will continue to follow this closely.

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 permit...

On the 21st of July 2026 JP Morgan announced that they have liquidated the shares underlying the ADRs of Rosneft: https://api.markitdigital.com/jpmadr-public/v1/cms/document?cmsId=88b769796a7f408d9386afac6a01fd3f&sequenceNo=7 JP Morgan sold the underlyings shares for $1.832142 per share, so $1.832142 per ADR. After fees and the correction for missing underlying shares due to forced conversion the cash distribution per ADR will be $$1.780982 upon cancellation of the ADRs. The liquidation sale was executed at a significant discount to the current price at the Moscow Stock Exchange (MOEX). The current MOEX price is approximately 345 Rubles per ordinary share (so 345 Rubles per ADR). JP Morgan has so far sold the underlying shares of five Russian ADR-programs at significant discounts to the share price at the MOEX: Rosneft, Sberbank, Magnit supermarkets, Mobile Telesystems and Novorossiysk Commercial Sea Port (NCSP). The liquidation by JP Morgan also makes it more easy to establish dam...

EAHCISS has been following the cash distribution by JPMorgan, as a result of the liquidation of the shares underlying the Sberbank ADRs (see https://news.eahciss.org/2026/06/jp-morgan-liquidated-shares-underlying.html?m=1 ), closely. We decided to give the process various weeks and many investors have now received the cash distribution. However many brokers have not yet credited the cash or wrongfully claim that the cash has been frozen due to sanctions. EAHCISS has set up a small survey to get a more precise overview of the current issues and will help us to determine which parties should be contacted by EAHCISS to increase pressure to distribute the payments. Please complete the survey if you possessed Sberbank ADRs at the time of liquidation by JPMorgan and share the survey with other investors. The survey can be accessed via this link: https://forms.gle/HRjTDbpKMrZDgBFP7 We plan to publish the results next week.

On June 1st 2026 Presidential Decree 377 was published ( http://publication.pravo.gov.ru/document/0001202606010019 ). This decree extended the type C regime, resulting from decree 95 from the 5th of March 2022, to payments resulting from bank (term) deposits.  At the time we did not write a post about this, because in our analysis the changes would not affect many retail investors, because the regime does not apply to current accounts used for normal banking payments, and because decree 95 only applies to monthly payments that are above the 10 million Rubles montly threshold.  Yesterday, the Central Bank of Russia confirmed our interpretation and stated ( https://www.cbr.ru/Crosscut/LawActs/File/12214 ) that the 10 million Ruble threshold is a monthly threshold per account holder and that normal current bank accounts are do not fall under the scope of the extension by decree 377. The Central Bank of Russia also confirmed that term deposits can be extended automatically, thereb...

Earlier we reported on the extended deadline (until December 31st 2026) for the share distribution by Rusagro ( https://news.eahciss.org/2026/02/friendly-shareholders-of-cypriot.html?m=1 ).  In our previous post we also shared our legal analysis that holders of depositary receipts from jurisdictions unfriendly to Russia are not legally able to participate in the share distribution during the extended period.  Rusagro has confirmed to EAHCISS that they share this legal interpretation: "Under paragraph 21 of Article 7 [of Federal Law 470-FZ of the 4th of August 2023], it is correct that residents of unfriendly countries do not have the right to receive shares of PJSC Rusagro Group." However, in all the documents published by Rusagro ( https://www.rusagrogroup.ru/en/investors/news-events/press-releases/single-view/article/1421/ ) Rusagro seems to apply the same criteria as during the first period of the share distribution and provide the impression that holders of depositary rec...

JSC Rakurs Invest, the custodian for the shares underlying the depositary receipts of Etalon, has now confirmed that, in accordance with Article 5 of the Federal Law of 04.08.2023 No. 452-FZ "On Amendments to Certain Legislative Acts of the Russian Federation", holders of depositary receipts (ADRs / GDRs) of ETALON GROUP PLC (ISIN US29760G1031) have the right to carry out forced conversion of depositary receipts into local Russian shares starting from July 08, 2026. This process does not require any cooperation from your Western broker and takes place under Russian law. The deadline for submitting documents for participation in the forced conversion is November 5, 2026 (inclusive).  More information can be found on the website of Rukurs Invest: https://rakursinvest.ru/services/conversion/ Given the complexity of the procedure, and the need to work with local Russian notaries and translators, we strongly advise to consider working with a local Russian representative and to sta...

Gazprom paid a record dividend of 51.03 Rubles per ordinary share over the first 6 months of 2022. These dividends were not paid on ADRs due to the legal restriction of Clause 2 of Part 5 of Article 6 of the Federal Law of April 16, 2022 No. 114-FZ "On Amendments to the Federal Law "On Joint-Stock Companies" and Certain Legislative Acts of the Russian Federation" that was present back in 2022. Gazprom recently confirmed in their annual report over 2025 (for English version: https://drive.google.com/file/d/1LG8DMtSqVtdqNPoryoDAfJfR-hbKr3i1/view?usp=drivesdk ) that over 100 billion Rubles (over a billion Euros) of unpaid dividends were restored as retained earnings because the statutory period to claim these dividends expired. This amount is largely due to the past restriction on the payment on ADRs.  Dividends on converted ADRs In 2025 Gazprom paid approximately 11 billion Rubles in unpaid dividends. Magenta legal has reported that BNY (as the depositary ...

After the liquidation of the Sberbank shares underlying the ADR-program, various investors seem to wonder what the background is of this discount. Decree No. 81 of the President of the Russian Federation dated March 1, 2022, "On Additional Temporary Economic Measures to Ensure the Financial Stability of the Russian Federation" (Decree No. 81; https://www.consultant.ru/document/cons_doc_LAW_410578/ ) established a special procedure for the execution of transactions involving securities between residents of the Russian Federation and "persons of foreign states committing unfriendly acts". According to the general rule stipulated by Decree No. 81, transactions involving securities between residents of the Russian Federation and "unfriendly persons" are only possible with the permission of the Government Commission for the Control of Foreign Investment in the Russian Federation (the Government Commission). The minutes of the Government Commission meeting of th...

On the 8th of June 2026 JP Morgan announced that they have liquidated the shares underlying the ADRs of Sberbank: https://api.markitdigital.com/jpmadr-public/v1/cms/document?cmsId=520e5773254e470ba09e55b38bd59b9d&sequenceNo=1 JP Morgan sold the underlyings shares for $1.184027 per share, so $4.736108 per ADR. After fees and the correction for missing underlying shares due to forced conversion the cash distribution per ADR will be $4.476211 upon cancellation of the ADRs. The liquidation sale was executed at a significant discount to the current price at the Moscow Stock Exchange (MOEX) is approximately 322 Rubles per ordinary share (so 1,288 Rubles per ADR). JP Morgan has so far sold the underlying shares of four Russian ADR-programs at significant discounts to the share price at the MOEX: Sberbank, Magnit supermarkets, Mobile Telesystems and Novorossiysk Commercial Sea Port (NCSP). EAHCISS is trying to establish if ADR holders whose positions have been liquidated can now apply to c...

Today EAHCISS had a preparatory meeting with an member of the European Parliament (MEP) for the St. Petersburg International Economic Forum (SPIEF) at the European Parliament in Brussels. During the meeting a one-pager was presented and copies were provided to the MEP for meetings with Russian members of the Duma. The one-pager contains challeges identified by EAHCISS and proposed solutions. The one-pager is bilangual with one side in English and the other side in Russian. Our one-pager can be downloaded here: https://drive.google.com/file/d/143UdEwhk9tc84vwg-TcjkFpCVMTWPVHk/view?usp=sharing   There will also be at least one member of EAHCISS attending the Forum. We wish all attendees of the Forum fruitful meetings, conversations and dialogues.

The annual general meeting of Evraz PJSC will take place on the 11th of June 2026 in Nizhny Tagil, Russia. The agenda lists the following items: 1. On the distribution of profits (including payment (declaration) of dividends) and losses of PJSC EVRAZ based on the results of the 2025 financial year. 2. On the election of members of the Board of Directors of PJSC EVRAZ. 3. On the appointment of an audit organization of PJSC EVRAZ. Persons entitled to vote when decisions are made by the General Meeting of Shareholders of EVRAZ PJSC shall have the right to become familiar with the information (materials) provided to shareholders in preparation for the General Meeting of Shareholders, in the premises of the executive body of EVRAZ PJSC daily from 21 May 2026, excluding weekends and holidays, from 9:00 to 18:00, as well as during the meeting at the address: Nizhny Tagil, Metallurgov Street, Bldg. 1. More information can be found on the website of Evraz: https://www.evraz.ru/press-center/news...

Today Evraz shares started trading on the Moscow Exchange (MOEX). The official announcement can be found here: https://www.moex.com/n100160 The share price and trade volume can be followed on the website of the Moscow Exchange: https://www.moex.com/en/stocks/evrz Trading commenced at a price of approximately 80 Rubles per share. Earlier shareholders of the UK registered Evraz PLC had the opportunity to apply for a share distribution in shares in the Russian subsidiary. For every single share of Evraz PLC 2.68 shares of the Russian subsidiary could be distributed. It is this former Russian subsidiary (Evraz PJSC) that is currently trading on the Moscow Exchange.

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...

All members should now have received a personal invitation for the EAHCISS general meeting on the 6th of June 2026 by e-mail. We look forward to seeing many of you in person and to discuss experiences and investment ideas during the lunch or the networking drinks. Please don't forget to indicate you interest for the event by completing the registration form. A link to the registration form can be found in the e-mail. Please feel free to reach out via contact@eahciss.org if you have any questions.

EAHCISS will meet a Member of the European Parliament (MEP) that will visit the St. Petersburg International Economic Forum and will meet with members of the Duma during the event. The goal of the meeting in Brussels is to discuss the challenges that European investors in Russia are facing. Unfortunately, EAHCISS is not able to send a representative to the Forum itself, but is looking forward to provide input via the meeting with the MEP in Brussels.

Last year the EU introduced a transaction ban with several Russian banks, including Sberbank (see article 5h of Regulation (EU) 833/2014). After the transaction ban was imposed EAHCISS established contact with the head of the financial sanctions unit within the European Commission ( https://news.eahciss.org/2025/07/impact-of-eu-sanctions-on-eu-investors.html ). The correspondence spread over many months during which we reiterated and explained our request to add a 'prior contract' exception. In April 2026 this exception was added to the EU sanctions regulation (under paragraph 22 of article 1 of Council Regulation (EU) 2026/506 of 23 April 2026 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine). The shareholder agreement is such prior contract that establishes the legal basis for the payment of dividend payments from an enitity that is subject to the transaction ban.

In April 2026 JP Morgan accounced that it has liquidated the shares underlying the ADRs of Novorossiysk Commercial Sea Port (NCSP): https://api.markitdigital.com/jpmadr-public/v1/cms/document?cmsId=c440676901554f368872385d7eb55355&sequenceNo=4 JP Morgan sold the underlyings shares for $0.032996 per share, so $2.474700 per ADR. After fees and the correction for missing underlying shares due to forced conversion the cash distribution per ADR will be $ 2.389009 upon cancellation of the ADRs. The liquidation sale was executed at a significant discount to the current price at the Moscow Stock Exchange (MOEX) is approximately 8.40 Rubles per ordinary share (so 630 Rubles per ADR). JP Morgan has so far sold the underlying shares of three Russian ADR-programs at significant discounts to the share price at the MOEX: Magnit supermarkets, Mobile Telesystems and Novorossiysk Commercial Sea Port (NCSP).