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Showing posts with the label Sanctions

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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Lobby success: exception from EU transaction ban on Sberbank, VTB and other banks for payment of dividends

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.
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Impact of EU sanctions on EU investors

On the 18th of July 2025 the Council of the European Union introduced a transaction ban with many Russian financial institutions, including Sberbank. EAHCISS is concerned about the impact this transaction ban may have on European investors that cannot avoid transactions with these Russian financial institutions due to (automatic) dividend or interest payments. Today we sent a letter to the Council of the European Union and the responsible department within the European Commission (Directorate-General FISMA) to express our concerns. The full letter can be read via this link: https://drive.google.com/file/d/140ybZCyVZLWnwDPhg32ad09VVpvFMPqT/view?usp=sharing
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