EAHCISS News (English)

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).

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...

The annual general meeting (AGM) of EAHCISS will take place during the afternoon of the 6th of June 2026 in hybrid form. Members of EAHCISS can attend physically at a location located centrally in the Netherlands in person or via video connection. After the physical meeting there will be social drinks with the opportunity to chat with other members and the board. Members of EAHCISS will receive an email with more information and how to register for the AGM over the next two weeks.

On April 10, 2026, the Gerenal Meetingof O'KEY GROUP S.A. decided to suspend trading on the AIX (Astana International Exchange) in the Group's global depositary receipts (ISIN US6708662019) from May 8, 2026 and to terminate trading and exclude these GDRs (ISIN US6708662019) from the official list of the AIX from May 13, 2026. O'key Group GDRs have also been listed on the Moscow Exchange since December 2020. It is planned that after delisting from AIX, the GDR program will continue to be traded on the Moscow Exchange. More information can be found here: https://okeygroup.lu/press-center/press-releases/2026/2033/

Nanduq (formerly known as Qiwi) has launched a buyback tender offer for its depositary shares (ISIN US74735M1080). Nanduq is offering 4.3 USD per depositary share. Shareholders can sign up for the tender offer until the 17th of April. More information on the buyback offer can be found on the website of Nanduq: https://nanduq.com/investors/buyback/

We have received some questions about the Sberbank dividends over 2022 and 2023. The dividends over 2022 for ordinary shares held via Western nominee holders were returned to Sberbank and can be claimed until the 21st of April 2026 (that is when the 3 year statutory period expires). The dividends over 2023 (distributed in 2024) for ordinary shares held via Western nominee holders were transferred to the type C accounts of these nominee holders (such as Interactive Brokers or Citibank). Interactive Brokers has indicated to clients that they are working on the reconciliation in regards to the dividends over 2023 (they have to work out which clients directly claimed these dividends via Raiffeisenbank Russia). Once this process is completed Interactive Brokers is expected to start displaying the Sberbank dividends that have been paid on ordinary shares in the accounts of investors. Dividends on depositary receipts have not been paid over the years 2022, 2023 and 2024. These dividends shoul...

X5 Netherlands has notified investors that BNY has assisted in the mandatory conversion of X5 Global Depositary Receipts into Dutch Depositary Receipts. Holders that participated in the share distribution of X5 Russia are effectively denied ownership of X5 Netherlands shares. Investors can self declare that they did not participate in the share distribution of X5 Russia and become a Qualified shareholder (via Dutch Depositary Receipts) in X5 Netherlands. Only Qualified shareholders can transfer depositary receipts and participate in the planned cash distribution. More information can be found here: https://x5.com/wp-content/uploads/2026/03/stage-one-announcement_final.pdf

The Moscow Arbitration Court earlier ruled on the claim of PJSC EVRAZ (Evraz Russia) for debt collection in the amount of 97,588,032,616.97 rubles against Evraz Plc, as well as on foreclosure on property to repay the above-mentioned debt from Evraz Plc. On April 01, 2026, PJSC EVRAZ executed the court’s decision by foreclosing on the property of EVRAZ plc. This information was disclosed by Evraz PLC on the 3rd of April 2026: https://www.evraz.com/en/news-and-media/press-releases-and-news/evraz-plc-announces-the-entry-into-force-of-the-decision-of-the-moscow-arbitration-court-on-the-clai/

Interactive Brokers has today started to display the payment of Sberbank dividends in the accounts of investors that hold ordinary Sberbank shares via Interactive Brokers (not ADRs). We have confirmed that the dividends over 2024 today showed up in these accounts of clients of Interactive Brokers. The process in which Interactive Brokers displays the dividends confirms the procedure following from the Central Bank of Russia decision that mandates that dividends that are not claimed via the Russian custodian (which is Raiffeisenbank Russia for Interactive Brokers) are forcefully credited to the type C account of the Western nominee holder (in this case Interactive Brokers LLC).

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...

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...

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...

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...

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_...

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/

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