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Discounts applied upon liquidation of shares (underlying ADRs)

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...
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JP Morgan liquidated shares underlying NCSP ADRs

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).
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JP Morgan liquidated shares underlying MTS ADRs

In April 2026 JP Morgan accounced that it has liquidated the shares underlying the ADRs of Mobile Telesystems (MTS): https://api.markitdigital.com/jpmadr-public/v1/cms/document?cmsId=8043843bdfc5456fafcbf1f694cc0f6a&sequenceNo=1 JP Morgan sold the underlyings shares for $0.820352 per share, so $1.640704 per ADR. This amount is quite a bit less than the tender offer by MTS back in 2024 for 95 Rubles per ordinary share ( https://ir.mts.ru/en/tender_offer ). JP Morgan did not participate in the tender offer back then. After fees and the correction for missing underlying shares due to forced conversion the cash distribution per ADR will be $ 1.582695 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 220 Rubles per ordinary share (so 440 Rubles per ADR). JP Morgan has so far sold the underlying shares of three Russian ADR-programs at significant discounts to the share price...
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