Join the European Association for Holders of Commonwealth of Independent States Securities (EAHCISS)!

Many investors in Russian securities in Europe and the Americas struggle with the complexity surrounding these securities. EAHCISS is there to help. EAHCISS is a not-for-profit association under Dutch law that seeks to:

- Inform holders about the options for converting depositary receipts (ADR’s) into ordinary Russian or other CIS-securities.
- Inform holders about the current options for investing in Russian companies and other companies in the CIS.
- Inform holders on how to claim unpaid dividends on these securities, and the different rules that apply to ADR’s and ordinary securities.
- Provide invaluable contacts for investors (such as lawyers that can be used as a representative in Russia via a power of attorney to claim unpaid dividends).
- Keep holders informed about relevant legal developments such as sanctions. We are in regular contact with leading European law firms with expertise in securities law, sanctions law and collective redress.
- Provide a social community for investors in Russia and other CIS countries.
- Provide relevant company specific updates for bigger companies.
- Keep holders updated on the options for collective claims against brokers, custodians and competent authorities that acted unlawfully and caused financial damage to investors (for example by refusing to convert or transfer securities or by refusing to facilitate the payment of dividends).
- Lobby for changes in (sanctions) legislation or to receive clarifications. We have contacts with Russian government officials, the European Commission and members of parliament in European member states.
- Launch legal procedures to try and set legal precedents that help investors.
- Seek media coverage to support our goals. We have given interviews to Bloomberg and were covered in a Bloomberg article that received widespread attention.

How do I become a member?
Simply fill in the membership form here: Membership sign-up | EAHCISS |

Who can be a member?
Both retail investors and institutional investors can be members. We currently both have institutional investors and retail investors as members, although most of our members are retail investors. You do not have to be an EU resident. We have members from all over the world.

What are the membershipfees?
The current membership fee is 30 € per calendar year. Members also get access to a member only area, where we post guides (in progress), blueprints and other useful information.

Through this channel EAHCISS will publish relevant updates in English. There is a similar channel for updates in German: https://t.me/eahcissdeutsch

Razb0rka reports for EAHCISS members
Razb0rka (https://t.me/RAZB0RKA | https://boosty.to/razb0rka) frequently publishes analytical reports on Russian companies. Their reports are very informative and highly recommended (so check out their channel and consider subscribing to them on Boosty). EAHCISS received approval from Razb0rka to translate and republish the reports they issue (in Russian) in English and German in the EAHCISS member portal. We will start to do so over the coming weeks.

Gazprom IFRS report
The Gazprom IFRS report over 2024 was published today. We attached it for your convenience.

Razb0rka reports
EAHCISS members will find the first from Russian to English translated and republished Razb0rka report attached to today's newsletter and in the document section of the member portal.

Reuters article on the unblocking of funds by Euroclear
Reuters published an article today on the unblocking of funds by Euroclear: Exclusive: Europe to hand billions in frozen Russian cash to Western investors, sources say | Reuters

This unblocking of funds is essentially part of an asset swap. Under Russian legislation NSD used the money in Euroclear's type C account to pay / compensate Russian investors for dividend and bond payments that were frozen in NSD's account in Euroclear. Now Euroclear is using these frozen funds to compensate Western investors for the money NSD took out of Euroclear's type C account in Russia.

We will post a more extensive post on the Telegram channels over the coming days.

Razb0rka report on Gazprom
We have now translated (to English) and published the Razb0rka analysis on the Gazprom IFRS report over 2024.

All Razb0rka reports can be found in the members area of EAHCISS (under 'files'). You can login via the EAHCISS website (www.eahciss.org), please let us know if you face any problems.

Razb0rka report on Lukoil
We have now translated and published the Razb0rka analysis on the Lukoil RAS report over Q1 2025.

All Razb0rka reports can be found in the members area of EAHCISS (under 'files'). You can login via the EAHCISS website (www.eahciss.org), please let us know if you face any problems.

The exchange of 'blocked' funds
The article published by Reuters yesterday raised some questions by some members.

In this post we'll try to explain the situation.

On 19 March 2024, the President of the Russian Federation signed Decree No. 198 “On additional temporary measures of economic nature related to the performance of obligations under certain securities” (“Decree 198”): https://www.consultant.ru/document/cons_doc_LAW_472406/

Decree 198 establishes the procedure for receiving securities related payments owed to certain categories of holders from funds blocked in Type C accounts of nominee holders such as Clearstream and Euroclear.

Article 9 of Decree 198 sets out what the Central Securities Depository (National Settlement Depository, NSD) has to do to have its obligations to international securities settlement systems duly performed under Russian law.

NSD waived its rights to an equivalent amount of balances on its accounts with Euroclear and Clearstream Banking, which remained blocked under EU sanctions.

Then the EU changed the sanctions legislation to allow for the unblocking of these funds for which the ownership rights were 'waived' by NSD: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32024R3189

In Clearstream's audit report (https://www.clearstream.com/resource/blob/1317842/96440fcf7b24b5637ffbda59fc52edf3/cbl-annual-account-data.pdf) this has been explained on page 12 as follows:

"On 23 August 2024, Clearstream Banking S.A. informed its customers that on 15 August 2024, the NSD had debited the Bank’s cash balances under Russian Presidential Decree No. 198 and its accounts were brought to zero. NSD waived its rights to an equivalent amount of balances on its accounts with Clearstream Banking S.A., which remained blocked under EU sanctions. On 14 February 2025, the Bank informed its customers that it had received the authorisation of its National Competent Authority to unfreeze the balances to which NSD had waived its rights. Accordingly, it has offered its customers compensation for the balances seized in Russia. The Bank’s affected customers are entitled to USD 368 million in full and final settlement of their entitlement to RUB 34.1 billion. The compensation had the effect of making Clearstream Banking S.A. again liable to its customers resulting in a write on of the corresponding amounts to its balance sheet as a subsequent event."

Already in the beginning of April, Russian newspapers reported on the permission Euroclear had received to unblock these funds: https://www.vedomosti.ru/investments/articles/2025/04/03/1102008-zarubezhnie-investori-poluchat-kompensatsiyu

It apparently took some time before this was picked up by Western media.

Razb0rka report on Novatek
We have now translated and published the Razb0rka analysis on the Novatek RAS report over Q1 2025.

All Razb0rka reports can be found in the members area of EAHCISS (under 'files'). You can login via the EAHCISS website (www.eahciss.org), please let us know if you face any problems.

Razb0rka report on Transneft
We have now translated and published the Razb0rka analysis on the Transneft RAS (Russian Accounting Standards) report over Q1 2025.

All Razb0rka reports can be found in the members area of EAHCISS (under 'files'). You can login via the EAHCISS website (www.eahciss.org), please let us know if you face any problems.

Razb0rka report on Magnit Supermarkets
We have now translated and published the Razb0rka analysis on the Magnit IFRS (IFRS Accounting Standards) report over 2024. We attached the financial report for your convenience.

All Razb0rka reports can be found in the members area of EAHCISS (under 'files'). You can login via the EAHCISS website (www.eahciss.org), please let us know if you face any problems.

*Free Razb0rka report on Magnit*
Razb0rka made their report on Magnit available for free online: https://boosty.to/razb0rka/posts/437952bd-57cc-47db-8bb6-ed24350fa7bb

This provides us the chance to provide a free translation into English (see attachment). This allows subscribers to get a better understanding of what the Razb0rka reports look like.

Razb0rka report on Nornickel
We have now translated and published the Razb0rka analysis on the Nornickel RAS report over Q1 2025.

All Razb0rka reports can be found in the members area of EAHCISS (under 'files'). You can login via the EAHCISS website (www.eahciss.org), please let us know if you face any problems.

Razb0rka report on Yandex (not to be confused with Nebius!)
We have now translated and published the Razb0rka analysis on the Yandex IFRS (IFRS Accounting Standards) report over Q1 2025. We attached the financial report for your convenience.

All Razb0rka reports can be found in the members area of EAHCISS (under 'files'). You can login via the EAHCISS website (www.eahciss.org), please let us know if you face any problems.

Euroclear provided more information on the release of funds
We earlier reported on the information the Clearstream released in their annual report. Euroclear has now too reported on this matter in their annual report (attached, p. 190). We'll quote the relevant part:

"As of year-end 2024, Euroclear Bank holds amounts on restricted C- and I-accounts recognised off-balance sheet (see Notes II and III). These restricted accounts were opened unilaterally by NSD in 2023 in the name of Euroclear Bank as countermeasure to the interantional sanctions imposed. The amounts held on the restricted C- and I-accounts have significantly decreased and amount to resprectively to RUB 41.9 billion (0.4 billion €-equivalent) and RUB 9.7 billion (0.1 billion €-equivalent), compared to RUB 262 billion (2.6 billion €-equivalent) and RUB 19 billion (0.2 billion €-equivalent) last year.

Between April and September 2024, Euroclear Bank's type C-account has been seized or debited on several occasions following Russian decrees for an amount of approximately 2.8 billion €-equivalent for the benefit of NSD's sanctioned clients. These clients are consequently no longer entitled to the balance blocked in Euroclear Bank and these balances could potentially serve to compensate the affected clients if the competent authorities provide the authorisation to release these amounts. NSD I-accounts balances have decreased as NSD has paid out some of the underlying to bondholders outside of Euroclear Bank in RUB.

The EU has introduced in December a loss recovery and no liability clause to its Russian sanctions regime now allowing the competent authority of a Member State to authorise the release of cash balances frozen by a CSD and attributable to the National Settlement Depository (NSD) under certain conditions. Essentially, this new clause allows the Belgian Ministry of Finance to authorise Euroclear Bank to debit NSD's account with the amounts that have been taken from Euroclear Bank's accounts with NSD following Russian court decisions or in application of Russian countermeasures, so that Euroclear Bank can compensate its Participants. Euroclear Bank will only be able to pay out the compensation amounts once the Belgian Ministry of Finance has provided its authorisation."

Court Press Release in relation to Nord Stream II
The court in Zug (Switzerland) is responsible for the bankruptcy procedures of Nord Stream II. The court announced today (https://zg.ch/de/gerichte/zivil-und-strafrechtspflege/kantonsgericht#Mitteilung) that a debt restructering agreement was confirmed by the court. This should avoid the bankruptcy of Nord Stream II. The court's ruling has not yet been made public. We have attached the previous court ruling of the 9th of January 2025 for your reference. The full court press release consists of the following text (translated from German):

"Press release dated 9 May 2025
By decision of the Cantonal Court of Zug EN 2022 2 of 9 May 2025, the restructuring agreement (dividend settlement) of 30 April 2025 concluded between Nord Stream 2 AG and its creditors, including Annexes 1 and 2, was confirmed by the court. Pursuant to Art. 307 para. 1 SchKG, the decision on the debt restructuring agreement may be appealed under the Code of Civil Procedure. Pursuant to Art. 307 para. 2 SchKG, the appeal has suspensive effect, unless the appellate court decides otherwise. Since the decision of 9 May 2025 is not yet enforceable, the Cantonal Court of Zug does not provide any further information on the debt restructuring moratorium proceedings of Nord Stream 2 AG (cf. Art. 308 para. 1 lit. b SchKG)."