Evraz update - getting your shares settled
Congratulations to all that now received the transfer information from Evraz PJSC (formerly known as NTMK). The next steps depend on your holding method. If you opened an account with ROST and requested Evraz PJSC (NTMK) to transfer the shares to your account in ROST there is no further action required. The shares will be transferred over the next few days.

If you instructed Evraz PJSC (NTMK) to transfer your shares to your brokerage account you will need to instruct your broker to place a matching inbound instruction. From our previous experience this can be done after the settlement in the instructions, but it is better do so sooner rather than later.

For Cifra the normal online transfer form cannot be used. You currently need to send a ticket to Cifra support with the attachment / details provided by Evraz PJSC and request them to complete the paper transfer form for you. Support will then reply with a pre-filled form that you only need to print and subsequently sign and date. You can then return a scan of the signed form via a secure (make sure you start a secure session) message in the Cifra app or online portal.

For other brokers you or your representative may need to visit a branch in person. It is best to engage with your broker to discuss with them how to proceed.

Webinar on forced conversion of Ozon depositary shares
On the 29th of December at 14:00 CET (16:00 MSK) EAHCISS will host a webinar on the topic of applying for forced conversion of Ozon depositary shares (also referred to as depositary receipts). The webinar is free of charge and can be joined via Yandex Telemost: https://telemost.yandex.ru/j/34283511035516

"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 aim to inform investors in Ozon about the process of applying forced conversion of Ozon depositary shares into ordinary shares as a shareholder in Ozon.

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. There will also be room for questions.

In the post above you can download the calendar invitation.

Video and presentation of Ozon webinar
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 depositary receipts can be found on the website of Ozon: https://ir.ozon.com/en/redomiciliation.

Current situation regarding the payments of dividends - dividends on ADR's are again being paid
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 be claimed for at least 3 years after conversion of the depositary receipts into ordinary shares. This extended deadline for claiming missed dividends unfortunately does not apply to those dividends that could no longer be claimed because the (normally 3 year) period for claiming missed dividends had already expired before the entry into force of the new legislation. Some issuers, such as Rosneft, extended the 3 year period to 5 years and their dividends that were declared in 2022 have not yet been added to their retained earnings and can therefore be claimed for many years after the conversion of depositary receipts into ordinary shares.

Dividends are forcibly paid to your custodian if you do not claim them yourself during 'the first stage of claiming dividends'
Investors could previously claim missed dividends themselves in various stages if the broker did not provide the information required for the payment of dividends. The easiest and first stage was claiming the dividends via the relevant Russian custodian of the foreign nominee holder (your Western brokerage firm; for example Raiffeisenbank Russia for Interactive Brokers). The first stage lasts a couple of months. The second stage was claiming the missed dividends via the Russian issuer directly. On the 28th of August 2024 the Central Bank of Russia changed the framework for the payment of dividends and the changes have been maintained ever since, and also in the latest version of the 26th of December 2025.

Since the end of August 2024 the following applies: If the western nominee holder or the individual investor does not provide the required information about the individual investor during the first stage, the dividends will not be transferred to the personal account of the individual investor but will instead be transferred into the type C account that is opened in the name of the Western nominee holder. It is no longer possible for the individual investor to then claim these dividends via the issuer directly at a later stage once the first stage has passed. Although the advantage is that the dividends are not lost if the investor fails to claim them within 3 years, investors that want to have the dividends paid in their own personal account should now act in the first stage and apply for payment to the Russian custodian of their nominee holder.

Forced Conversion of Cian depositary receipts
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/).

Fees of Cifra Broker and how to pay for them
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 central securities depository (NSD) - would move the shares held in type C accounts to accounts in the shareholder registers that were directly opened in name of these Russian brokers. Under point 2.2.2. of the new fee schedule Cifra charges a holding fee of 0.25% per month for shares being accounted for in their accounts with the Russian registrars that maintain the shareholder registers.

Please note the requirement for Russian brokers to hold the shares in type C account directly via the shares registers ceased on the 31st of December 2025. The Central Bank of Russia has also established the procedure to transfer the shares back to the account of NSD to restore the common chain of custody. The Central Bank Decision can be accessed via the website of the Central Bank of Russia: https://cbr.ru/rbr/dir_decisions/rsd_2025-12-09_34_03/

Under the current fee schedule of Cifra Broker the 0.25% holding fee should no longer apply since it only applies to shares being held by Cifra via their direct accounts in the shareholder registers. As the shares have been transferred back to the central securities depository the holding of shares by Cifra via the registrars should no longer be the case.

How to pay for Cifra's fees
Normally the fees charged by Cifra will be automatically deducted from funds in your account. This can also be from previous dividend payments in your type C account with Cifra.

You can also transfer funds to Cifra. In our experience the most straightforward method to transfer funds to Cifra from outside Russia is to use the account of Cifra Broker with Raiffeisenbank Russia. Euros will automatically be converted into Rubles once the payment hits the account of Cifra with Raiffeisenbank Russia.

Last week we initiated a test payment using the bank details below in euros from a Dutch bank. The payment showed up in the Cifra account after one business day.

The bank details used were:
Account number (BBAN): 40701810900000001523
Account name:
Cifra broker LLC
Address of Cifra broker:
15, 1st Krasnogvardeyskiy proezd, Suite 18.02, Moscow, 123112, Russia
Bank:
AO RAIFFEISENBANK
Bank address:
SMOLENSKAYA-SENNAYA SQ 28
MOSCOW
BIC (SWIFT):
RZBMRUMM

Payment reference: "Client [your account number with Cifra]. Funding of the brokerage account under the Service Agreement". You can just copy the reference Cifra instructs you to use in the app.

Correspondent bank for payments in euros (only required if your bank asks for these details):
Raiffeisen Bank International AG
Address Correspondent bank:
Am Stadtpark 9, A-1030 Vienna, Austria
BIC (SWIFT) Correspondent Bank:
RZBAATWW
Account number with Correspondent bank:
001-55.025.928

Update fees Cifra Broker
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.

Dividends on ADRs of Ozon
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 account opened in the name of Bank of New York (BNY) as the depository bank for Ozon depositary receipts.

Possible exchange of Russian non-Ruble bonds in Ruble bonds
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

Claiming dividends on ADRs: Lukoil and Rosneft examples
In an earlier post we explained that ADR holders are currently again eligible to receive dividends payments on ADRs. Since our post various other organisations wrote articles about this topic, and many of our members also received this week's Lawflash from Morgan Lewis (https://www.morganlewis.com/pubs/2026/01/update-russia-introduces-new-rules-for-dividend-payments-on-depositary-receipts).

Because of the questions that we continue to receive about this topic we would like to take the recent dividend payments by Lukoil and Rosneft as an example.

Due to the complexity of the procedure it is generally recommended to claim these dividends with help from a Russian representative. EAHCISS can refer you to representatives that we have good experiences with.

If you successfully claim these dividends and are from a country that is considered unfriendly to Russia then the dividends will be paid into a type C account.

Lukoil example
The record date for Lukoil dividends over the first nine months of 2025 was the 12th of January 2026. The ADR program for Lukoil is managed by Citibank North America. The Russian custodian bank for the Russian ordinary shares underlying the Lukoil ADRs is Citibank Russia. Therefore investors that hold ADRs in Lukoil outside of Russian infrastructure can now, for a temporary period of a couple of months, request payment of dividends into their own personal account via Citibank Russia. More information about the procedure can be found on the website of Citibank Russia: https://www.citibank.ru/corporate/securities_services/

Any remaining dividends that have not been subject to a timely request for payment into the personal account of the investor will be locked in the type C account opened in the name of Citibank North America. Citibank North America may distribute these dividends once sanctions and counter sanctions (type C regime) have been lifted.

Rosneft example
The record date for Rosneft dividends over the first nine months of 2025 was the 12th of January 2026. The ADR program for Lukoil is managed by JPMorgan Chase. The Russian custodian bank for the Russian ordinary shares underlying the Rosneft ADRs is Raiffeisenbank Russia. Therefore investors that hold ADRs in Rosneft outside of Russian infrastructure can now, for a temporary period of a couple of months, request payment of dividends into their own personal account via Raiffeisenbank Russia. More information about the procedure can be found on the website of Raiffeisenbank Russia: https://www.raiffeisen.ru/corporate/depositary/securities/

Any remaining dividends that have not been subject to a timely request for payment into the personal account of the investor will be locked in the type C account opened in the name of JPMorgan Chase. JPMorgan Chase may distribute these dividends once sanctions and counter sanctions (type C regime) have been lifted.

Update on Cifra's fees - fees have been lowered
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/

What happens to Russian ADR's?
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_za_osushchestvleniem_inostrannykh_investitsii_v_rossiiskoi_federatsii_ot_15_oktyabrya_2024_goda__2681). We do not have indications that the depositary banks are currently actively pursuing similar deals or are in contact with the government committee to apply for permission.

The depositary banks also have the discretion to open the books and facilitate conversion even after the depositary program has formally ended. Many depositary banks facilitated conversion back in the fall of 2024 for depositary programs that had formally ended.

We feel that depositary banks may again decide to open the books for conversion should such opportunity open up. At the same time the depositary banks will probably start preparations for selling the ordinary shares underlying the depositary receipts, hopefully in deals that do not involve the huge discounts that currently applied.

Compensation from brokers for failed ADR conversion
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 Dutch financial arbitration board Kifid ordered Saxo Bank to compensate an investor for the amount of unpaid Gazprom dividends as a result of a failure to convert the ADRs (see: https://www.kifid.nl/media/dnfks2kh/uitspraak-2025-0150.pdf).

Voluntary conversion of Okey group ADRs
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. Please be advised that RCS Issuer requires payment of previously unpaid depositary fees (even if you were not a shareholder at the registration date for the depositary fees) in addition to the normal conversion fees. These previous depositary fees currently amount to 0.04 EUR per ADR and will be 0.06 EUR per ADR from the 9th of March 2026. This means that investors will incur serious conversion costs compared to the current share price on the AIX.

"Friendly" shareholders of Cypriot Rusagro ADR's can apply for direct ownership in the Russian Rusagro entity until the end of 2026
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 31st of December 2026 (see the request of the 18th of November 2025; https://kad.arbitr.ru/Card/ba4ee5c8-64e4-47b3-8734-183da7d7dae0), which was granted on 11th of December 2025. Hence Russians and shareholders from countries friendly to Russia can now apply until the 31st of December 2026 for shares in the Russian entity of Rusagro, even if they missed the initial deadline.

Shareholders from jurisdictions unfriendly to Russia have the opportunity to transfer the right to receive shares in Rusagro Russia to a Russian person / entity that can then claim this right until the end of December 2026.

More information and the necessary forms can be found on the website of Rusagro: https://www.rusagrogroup.ru/en/investors/news-events/press-releases/single-view/article/1421/

It will be interesting to see if other companies will ask for an extension of this period. Many Evraz PLC shareholders missed the deadline for the share distribution in Evraz NTMK (Evraz Russia).

NSD did not extend the period of fee waiving
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 competent authorities.

We will soon do a write up on several court cases that EAHCISS contributed to with expertise. In one of the cases the Dutch court ruled that the Dutch competent authority had unjustly limited the time period for which the authorisation to make funds available to NSD whilst converting Russian ADRs was valid. The court recognized that in practice not all securities could be converted in the relevant timeframe and that a sale of the underlying ordinary shares was also not practically possible (see Court of Gelderland 20 March 2026, ECLI:NL:RBGEL:2026:2225 https://uitspraken.rechtspraak.nl/details?id=ECLI:NL:RBGEL:2026:2225). Earlier, an Austrian court had ruled that the Austrian competent authority had rightfully rejected the request for authorisation because the request was submitted after the deadline (see Bundesverwaltungsgericht Republik Österreich 21st of May 2024, https://ris.bka.gv.at/Dokumente/Bvwg/BVWGT_20240521_W276_2288682_1_00/BVWGT_20240521_W276_2288682_1_00.pdf).

Payment of Sberbank dividends displayed in Interactive Brokers
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).

Evraz Russia foreclosed on assets of Evraz PLC
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/

X5 has now largely executed a mandatory conversion of X5 Global Depositary Receipts into Dutch Depositary Receipts
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

Sberbank dividends over 2022 and 2023
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 should have been returned to Sberbank as the issuer and can currently be claimed for three years after conversion of the depositary receipts into ordinary shares.

Under the current framework holders of depositary receipts of Sberbank should be able to receive payment of the dividends over 2025.

The payment of dividends over 2025 will be decided during the general meeting of shareholders of Sberbank later this year.