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...

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...

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 ...

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...

Earlier this month we wrote about the change in Russia legislation that allows for the payment of dividends on depositary receipts (ADRs) of all Russian issuers. Earlier we also wrote about the dividend of 143.55 Rubles per Ozon share / depositary share that was approved by the general meeting of shareholders of Ozon on the 10th of December 2025, with a dividend registration record date of the 22nd of December 2025. Ozon has now published the procedure for the payment of the recent dividend to ADR holders. The procedure is similar to claiming dividends of other issuers. Applications for the payment of dividends can be submitted up to the 20th of February 2026 to the registrar of Ozon, which is Register Proton. The full procedure is published on the website of Ozon under the header 'dividends': https://ir.ozon.com/corporate-governance It is our understanding that the dividends that are not claimed by investors directly before the 20th of February 2026 will be stuck in a type C a...

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...

Many investors in Globaltrans have been waiting for the dividend payment that distributes the receipts of the recent sale of the Russian subsidiaries. Globaltrans Investment PLC has now announced that the payment of the special interim dividend to the eligible registered shareholders (including the Depositary Bank) has been dispatched (https://www.globaltrans.com/investors/news/detail/2572). The distribution of the special interim dividend was approved by the decision of the Board of Directors of the Company on 18 April 2025 (https://www.globaltrans.com/investors/news/detail/2557). In accordance with the Depositary Agreement between the Company and the Depositary Bank, the dividend payment to holders of the Company’s Global Depositary Receipts will be arranged by the Depositary Bank.

During today's AGM for Sberbank, that was held via video-attendance, the  shareholders approved the payment of dividends. The dividend over 2024 is 34.84 Rubles per ordinary share and will be paid to shareholders that hold shares at the end of day on July 18th 2025. ADR holders (holders of depositary receipts) will not be able to receive dividends, but may claim dividends after conversion of ADR's into ordinary shares. More information can be found here: https://www.sberbank.com/investor-relations/corporate-governance/annual-meeting-2025  

In this post we provide a fourth update on recent Russian court decisions. Case 4: Who needs a lawyer to claim Rosneft dividends in court...? The fourth case involves mr. Bychkov that held ADR's (depositary receipts) of Rosneft via the Cypriot broker EXT Ltd. and had them successfully converted via forced conversion. Mr. Bychkov then requested Rosneft to pay the unpaid dividends, which was only about 17,000 Rubles. Rosneft refused the request, stating that it wasn't sufficiently proven that mr. Bychkov owned the ADR's at the Rosneft dividends over 2021 that were returned by Raiffeisenbank to Rosneft (in the amount of 6,915,398,471.46 Rubles!!) included the dividends that were due to mr. Bychkov. Mr. Bychkov then went to court himself, without a lawyer. The relatively low claim of 17,000 Rubles would make it economically non-viable to be represented by a lawyer. Mr. Bychkov also didn't attend the hearing, probably due to travelling costs. The court established tha...

In this post we provide a third update on recent Russian court decisions. Case 3: Raiffeisenbank was ordered to pay financial compensation for failing to execute a request for forced conversion The third case involves mr. Nesterenko that held ADR's (depositary receipts) of MTS via Interactive Brokers. Mr. Nesterenko requested Raiffeisenbank forcefully convert of his MTS ADR's. Raiffeisenbank Russia refused the request which a general statement that included various reasons why such a request can be rejected. Mr. Nesterenko considered the rejection to be unlawful and went to court to request compensation from Raiffeisenbank. The court determined that mr. Nesterenko submitted the documents that he could reasonably gather and that Raiffeisen put unreasonable conditions in place. The court also considered that Raiffeisenbank, as a professional bank, has it's own resources to verify the information that was provided. The court decided that Raiffeisenbank had to pay compens...

In this post we provide a first update on recent Russian court decisions. These court decisions were kindly provided by Irina Sibirina from the legal firm Itlektis.ru . More case law on Sberbank securities will follow soon. Case 1: Forced transfer of Rosneft shares and unpaid Rosneft dividends The first case involves an investor, mr. Gubaev, that bought Rosneft shares via the Swiss CBH Bank (the case materials speak in one section about directly buying ordinary shares but refer to converted depositary shares in another section). He applied to get his ordinary shares forcefully transferred from CBH Bank to his Russian brokerage account with ATON. According to the court materials, the chain of custody involved The Belgian Branch of Bank of New York Mellon and Citibank Russia. The Russian appellate court ruled in October 2023 that Citibank Russia had wrongfully denied the request for a forced transfer and ordered Citibank Russia to carry out the forced transfer. The full case materials ...

Gazprom declared record dividends of 51.03 Rubles per ordinary share (=102.06 Rubles for the 2 ordinary shares that represent 1 depositary receipt [ADR]) over the first half of 2022. Many investors were not able to convert their Gazprom depositary receipts into ordinary shares because of the refusal by brokers and (sub) custodians to facilitate this. As many of you are aware: Gazprom depositary receipts are not eligible for the payment of dividends due to changes in Russian legislation in April 2022. Once the depositary receipts are converted, investors can claim the unpaid dividends. At least 800 million euros in unpaid dividends is likely to fall back to Gazprom post September 2025. This is due to the statute of limitations in relation to unpaid dividends (3 years). In practice the amount will likely be higher as many investors that converted their ordinary shares post October 2022 have not yet claimed unpaid dividends due to the complexity of the procedure. According to Gazprom, 5.9...