OFAC has authorized transactions with NSD till 12.10.2024 – possible option for prolongation of DR conversion
The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) has issued 2 general licenses under which certain transactions with the Russian National Settlement Depository (NSD) can be made until 12.10.2024. This means that communication with the Russian NSD will be possible for at least the next 2,5 months.
Given that the recent closure of the books by the American custodians for cancellation of the depositary receipts (DRs) on 01.08.2024 (we wrote about it a few days ago) was triggered by the relevant OFAC sanctions, we believe that DR holders can require their brokers to transmit booking instructions to the American custodians till 12.10.2024, as the NSD's participation in this procedure is again possible due to the respective general licenses of OFAC.
MAGENTA Legal strongly recommends that DR holders file their instructions for the conversion of the DRs as soon as possible.
The information provided in this message is for general guidance only and does not constitute legal or financial advice. MAGENTA Legal accepts no liability for any actions (or inactions) based on the information provided. Please consult with your legal and/or financial advisor.