Transfer of all shares of the Russian companies kept on the type “C” (“S”) accounts from NSD to the Russian registrars has commenced
In accordance with the decision of the Central Bank of Russia dated 03/10/2024, based on the decree of the President of Russia No. 840 dated 02/10/2024, the transfer of all shares of the Russian companies kept on the type “C” (“S”) accounts in GPB/other nominal holders within the Russian National Settlement Depository (NSD) has commenced. The transfer is made from NSD to other Russian registrars (based on the respective issuer of the shares, for example, for GAZPROM it is registrar “Draga”). As can be concluded from the information available, NSD will no longer take part in this process.
GPB has started to inform the clients that the type "C" (“S”) depot account opened in the name of the client with GPB, where the client's shares are registered, will remain unchanged and that the number of shares registered will not be affected. However, we also know that the shares can be at least temporarily recorded at a special Section 2 of the depot account, being blocked there for a certain period of time. At the same time, they have already been blocked before, and therefore, we currently do not see any direct consequences for the clients, at least the moment.
To the best of our knowledge, and also confirmed by various multiple resources, there is no action required of clients maintaining shares at GPB type "C" (“S”) depot accounts.
Disclaimer: please note that this subject is still new and no practice and/or jurisprudence can be found on the matter as of today. We advise that monitoring of this issue be exercised in case any developments of the regulation, interpretation thereof by state and non-governmental structures or the practice of its implementation appear.