Payment of dividends on DRs and converted shares: new opportunities for investors
Dividends on DRs are being paid again
As many of you know, in the Spring of 2022 Russian lawmakers prohibited payment of dividends under almost all ADR and GDR programs, and DR holders who wished to receive dividends had to go through complex procedures to convert DRs into shares and claim dividends.
However, this ban has been lifted at the end of 2025 and dividends on DRs can once again be paid - although it is not entirely clear how exactly (and how reliably) this mechanism will work in technical terms for various DR programs (and especially - for foreign DR holders).
New deadlines for claiming dividends on converted shares
Another important change is that the deadline for claiming dividends on shares converted from DRs is not 3 years from the date of the respective decision of a Russian JSC anymore (though some companies set longer deadlines). Now it is 3 years from the date of crediting of the shares converted from DRs to the owner's account.
However, there is a problem: this new approach applies only to dividends that, as of 28 November 2025, were NOT "restored" by Russian JSCs as part of their retained earnings (i.e. - not returned to the company after expiration of the above term).
So, if the deadline for claiming dividends already passed before 28 November 2025 (for example, as it happened for dividends of Gazprom for 1Q 2022, which finished to pay them in September-October 2025), it will not be possible to collect such missed dividends.
But it should be noted that many companies distribute dividends quite often, and the deadlines for each specific distribution must be checked separately so as not to miss the opportunity to collect dividends under various distributions. A good example can be Lukoil or Tatneft dividends.
Therefore, investors (especially foreign ones) have new opportunities to receive the funds owed to them, although it should be noted that other restrictions (such as special regime of type "C" accounts, etc.) remain in place and must be taken into account.
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