EAHCISS News (English)

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

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...

Further to our last post, we would like to note that Cifra has published a new fee schedule that will enter into force on the 15th of January 2026. In that fee schedule a fee has been added for holding shares in type C accounts via NSD. This fee is high. It is set at 0.25% of the holdings in the type C account per month (see point 2.1.3. in the new fee schedule). The new fee document can be accessed via this website: https://cifra-broker.ru/about/company/news/ooo-tsifra-broker-obnovilo-reglamentiruyushchie-obsluzhivanie-klientov-dokumenty-57044/ Unfortunately, it is our understanding that other Russian brokers also started charging similar fees to hold funds via type C accounts. Investors may consider opening accounts in the share registers to see if holding via the share register may be more cost effective for investors. In the mean time we aim to discuss the new fee structure with Cifra Broker.

Many western investors in Russia use Cifra Broker as their brokerage firm.  Cifra has recently updated their fees. Investors that hold shares via a type C account may have noticed an additional fee being charged recently. This is due to the updated fee schedule by Cifra Broker. This fee does not display in the 'cash movements' in the Cifra App, but can be viewed via brokerage reports. In addition the fee can be seen on the Russian tax tickets that are sent to your email address after paying for the fee.  The fee that Cifra charged is 0.25% of the value of the type C account. If the shares are not traded and no trading price can be established then 0.25% will be charged over the nominal value. The fee is a holding fee for holding shares by Cifra directly in the share registry of the various Russian issuers.  Some may remember that Decree 840 of the President of the Russian Federation mandated that Russian brokers - that would normally hold their shares via the Russian cent...

In October 2025 Cian underwent redomiciliation from Cyprus to Russia. The 120 day window for the forced conversion of Cian depositary receipts started on the 15th of December 2025. Owners of depositary receipts have until the 14th of April 2026 (inclusive) to apply for forced conversion via Rakurs Invest. The procedure is similar to other procedures for forced conversion that we discussed in more detail recently (see the webinar on Ozon). More information can be found on the website of Cian (https://ir.ciangroup.ru/ru/shareholders/conversion/) and on the website of Rakurs Invest (https://rakursinvest.ru/services/conversion/).

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...

  EAHCISS and Irina Sibirina at Itlektis jointly hosted a webinar today on the topic of forced conversion of Ozon depositary shares into ordinary Russian shares. We have now uploaded the presentation and the video of the webinar on YouTube . The presentation can be downloaded here. Webinar title: "I don't want no liquidation!" How to apply for forced conversion of Ozon depositary shares into ordinary shares as a shareholder in Ozon. In this webinar we inform investors in Ozon about the process of applying forced conversion of Ozon depositary shares into ordinary shares as a shareholder in Ozon. It is highly recommended to apply for forced conversion in order to prevent liquidation of your depositary shares in Ozon by BNY (the depositary bank). Topics that will be covert are the opening of an account to receive ordinary shares in Ozon, the legal framework and how to practically go through the process of forced conversion. More information on forced conversion of Ozon ...

Yesterday was the last day for submitting applications for obtaining Evraz NTMK shares for Evraz Plc shareholders. Congratulations to all that managed to apply successfully.  Today there were two Evraz updates that we wanted to inform you about.  1. Transfer of Rasp en Timir from Evraz Plc to Evraz KGOK   Today Putin authorized the transfer of RASP ("Raspadskaya") and Timir shares from Evraz Plc to a subsidiary of Evraz NTMK (Evraz KGOK). Although we do not know the exact arrangement, it is likely that a lot of value was, or will be transferred from Evraz Plc to Evraz NTMK.  2. Evraz NTMK announced a delay in sending transfer instructions   Evraz NTMK announced today that, due to the high number of applications received, they need a bit more time to send out the settlement instructions. Evraz NTMK announced that they will now send the reference and settlement information between the 5th of December and 8th of December 2025. If you do not receive the settlemen...

From the 1st of December 2025 "Reestr Proton", the new Russian registrar of Ozon, will start accepting applications for the forced conversion of depositary shares of Ozon. Ozon recently underwent redomiciliation from Cyprus to Russia. Applications for forced conversion can be submitted until the 31st of March 2026.  It is likely that this may be the only chance for holders of depositary shares to convert their depositary shares of Ozon into ordinary shares. If one does not participate in the current procedure the ordinary shares underlying the depositary receipts may well be liquidated for a discount once the depositary bank BNY may be able to do so. Magenta Legal recently published a video in which they explain the process. EAHCISS may organise a webinar on this topic too to help investors navigate the fairly complex procedure of forced conversion. The video by Magenta Legal can be viewed via YouTube: https://youtu.be/Xir-ZeLMeOM

Yesterday was the first day of trading of Ozon on the Moscow stock exchange after the process of redomiciliation from Cyprus to the Russian Federation was completed.  The 11th of November 2025 was also the day that Reestr-Proton, the registrar for Ozon, published the procedure for the forced conversion of depositary shares into local ordinary shares. This information can be found here: https://reestr-proton.ru/for_shareholders   EAHCISS is contemplating hosting a webinar to explain the process of forced conversion of Ozon depositary shares.  It is well possible that shareholders that do not apply for forced conversion may not have the chance to obtain ordinary shares of Ozon afterwards and that BNY will liquidate the Ozon shares that underly the depositary shares if they see a possibility to do so. Unfortunately voluntary conversion of depositary shares of Ozon has, in practice, not been possible due to a global lock that was placed on the depositary shares by the DTC in ...

In this post we provide a sixth update on recent Russian court decisions.  Case 6: If you did not apply for 'Forced Conversion' in 2022 you can't ask a Russian court to force Raiffeisenbank to do so now  This case involves Ms Staroseltseva that bought depositary receipts of Polyus in August 2023. She was allowed to do so since Polyus was granted an extension of their depositary receipts program beyond April 2022 by the Russian government committee.  However, as the purchased the depositary receipts beyond the deadline for forced conversion in 2022, she could not participate in the forced conversion.  She therefore decided to start legal proceedings against BNY and Raiffeisenbank Russia in the Russian courts. She was trying to get a Russian court order that would force Raiffeisenbank Russia to take the underlying shares out of the depositary account for the Polyus depositary receipts program and to transfer these ordinary shares to her own account.  The Moscow ar...

BNY has put out a notice in which they inform holders of depositary receipts of Solidcore (formerly known as Polymetal; AUCOY) that they have sold the shares underlying the depositary receipts. BNY will process a cash distribution of $ 4.09 per depositary receipt.  The notice can be found via this link: https://www.adrbny.com/content/dam/adr/documents/corporate-actions-dr/files/AD2000242.pdf

Magenta Legal has now also published a video on the share distribution of Evraz NTMK shares that Evraz Plc sharholders can apply for. The video focuses on slightly different aspects than the video published by EAHCISS so it may also be an interesting video for those that joined or watched the webinar hosted by EAHCISS. https://youtu.be/dzRQAKEX-zk

Thank you all very much for joining yesterday's webinar on claiming Evraz NTMK shares! We have now published the video on YouTube ( https://youtu.be/G5EAAPb1GyI ). I want those shares! How to apply for Evraz NTMK shares as a shareholder in Evraz Plc. In this webinar, hosted on the 27th of September 2025, we aim to inform investors in Evraz about the process of applying for direct ownership in Evraz NTMK.  Topics that are covert are the opening of a brokerage account with Cifra broker, the basic conditions for claiming Evraz NTMK shares and how to go through the process if you either were issued Evraz share certificates before August 5th 2022 (lucky you!) or if you held your shares via a broker after the 4th of August 2022 (this means the process is a bit more complicated). We have added the presentation from the webinar as an attachment for your reference.

Thank you all very much for joining our webinar on claiming Evraz NTMK shares today! We'll aim to make the video available on our YouTube channel. We have added the presentation from the webinar as an attachment for your reference.