Shortly after the NSD (the Russian central securities depository) was placed on the sanctions list by the EU, NSD started waiving fees. This was done to allow for certain transactions to continue (such as the conversion of depositary receipts into ordinary shares), without a payment being made to NSD as a sanctioned entity. This fee waiving period lasted until the 31st of December 2025 and has since not (yet?) been extended (see https://www.nsd.ru/en/tariffs/ ). We earlier noted that Russian securities in type C accounts (including the ordinary shares underlying depositary receipts) were transferred back to NSD after NSD had been cut out of the chain of custody for a while after NSD was sanctioned by OFAC (see Decree 840 of the 2nd of October 2024, that wasn't extended). Unfortunately, this means that the NSD may levy charges again for a transfer of securities out of the account of the depositary banks and foreign nominee holders. Hence one would require an authorisation from comp...