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)."

Razb0rka report on Ozon
We have now translated and published the Razb0rka analysis on the OZON 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.

Razb0rka report on Tatneft
We have now translated and published the Razb0rka analysis on the Tatneft 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 Alrosa
We have now translated and published the Razb0rka analysis on the Alrosa 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.

Amount of unpaid dividends for Gazprom
Gazprom declared record dividends of 51.03 Rubles per ordinary share (=102.06 Rubles for the 2 ordinary shares that represent 1 depositary receipt [ADR]) over the first half of 2022.

Many investors were not able to convert their Gazprom depositary receipts into ordinary shares because of the refusal by brokers and (sub) custodians to facilitate this. As many of you are aware: Gazprom depositary receipts are not eligible for the payment of dividends due to changes in Russian legislation in April 2022. Once the depositary receipts are converted, investors can claim the unpaid dividends.

At least 800 million euros in unpaid dividends is likely to fall back to Gazprom post September 2025. This is due to the statute of limitations in relation to unpaid dividends (3 years).

In practice the amount will likely be higher as many investors that converted their ordinary shares post October 2022 have not yet claimed unpaid dividends due to the complexity of the procedure.

According to Gazprom, 5.90 percent of the share capital is currently still represented by depositary receipts: https://www.gazprom.com/investors/stock/. This amounts to approximately 1.4 billion ordinary shares.

EAHCISS is exploring options for (funding) class actions against financial institutions that misinformed investors about their option to convert and applicable sanctions or simply refused to facilitate the conversion of depositary receipts into ordinary shares. We will keep you updated in due course.

Razb0rka report on Inter RAO
We have now translated and published the Razb0rka analysis on the Inter RAO 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.

New round of automatic DR-conversion
The Russian Central Bank took a decision on the 6th of June 2025 that provides for a new round of automatic conversion of DR's ([global or American] depositary receipts / GDR's / ADR's) that are stored in Russian infrastructure.

The decision by the Russian Central Bank is based on Russian legislation that allows the Central Bank of Russia to set the date for a (new) round of automatic conversion. The legislation does not allow the Central Bank of Russia to set a date for a new round of so called 'forced conversion', where investors can request the 'forced conversion' of DR's stored outside of Russian infrastructure, without any support of western brokers or depositary banks. The date for forced conversion / forced transfer (of ordinary Russian shares) was set in the law itself.

Unfortunately, this new round of automatic conversion will not be helpful to most western investors that seek to convert their Russian DR's, as their DR's are kept with non-Russian brokers.

To our knowledge it hasn't been possible to transfer DR's into Russian infrastructure. Even Russian brokers with sub-accounts with western brokers (such as Cifra broker) have not willing to accept inbound transfers DR's over the last years.

Fix Price share swap program
Fix Price has announced a share swap program. The share swap allows ADR-holders to swap the ADR's in Fix Price for ordinary shares of the Russian PJSC Fix Price. Fix Price has communicated that the transaction should be considerd economically neutral and that Kazakh holding of Fix Price will remain the majority shareholder in PJSC Fix Price. All information can be found on: https://exchange.fix-price.com/en/. Interested investor are advised to read the memorandum that is published on the website above.

Unfortunately, investors from countries that are considered unfriendly from a Russian perspective cannot participate in the share swap, unless the investor received permission from the Russian government. This permission can be requested from the Government Commission for Control over Foreign Investments in the Russian Federation (http://government.ru/department/560/) on the basis of article 1(b) of Decree of the President of the Russian Federation dated 01.03.2022 No. 81 (as amended on 20.05.2024) "On Additional Temporary Economic Measures to Ensure the Financial Stability of the Russian Federation".