Russian issuers shall take action before 5 May 2022 to close foreign depositary receipt programmes and terminate contracts they used to place securities under foreign law. These procedures will take place within the time limits set by such contracts. To further convert foreign depositary receipts into shares of a Russian issuer, their holders will have to prove that they owned them on the day the ban came into force.

Russian issuers have the opportunity to maintain depositary receipt programmes by a decision of the Government of the Russian Federation in accordance with the procedure approved by it. An application for such a permit should also be submitted no later than 5 May 2022.

In the case of a positive decision, no additional actions will be required from Russian issuers and holders of depositary receipts. If the application is declined, the procedure for terminating the contract with a foreign bank — depositary receipt issuer should be launched within five business days.

Financial markets megaregulator