FAQs about Presidential Decree No. 665 of 09 September 2023

1. Is it possible to submit the documents as per your comments after 60 days but before 90 days from the date of payment?
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There is no restriction on the acceptance of documents, but if additional documents are received after the 60th day, the payment will be made in foreign currency if the Application is accepted.

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2. When submitting the set of documents for subsequent payments, do I need to submit another set of constituent documents?
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There is no need to resubmit constituent documents if there are no changes since the date of submission of the previous set of documents and if the Application has been duly marked.

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3. I am an individual holder. The new application will be signed for me by a representative, what documents should I provide additionally?
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In this case, you must additionally submit Form AA106 filled out for the representative, a power of attorney and the representative's passport. Forms in which the above documents need to be submitted and other additional information can be found on the NSD website: Documents to be submitted to NSD (nsd.ru).

Please note that the representative's signature must be notarised or certified by an NSD employee.

If a new application is submitted in addition to the documents that were previously sent concerning the payout, the Notification that These are Additional Documents (Information) to a Previously Submitted Application must also be submitted.

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4. We are a corporate holder. What documents do we need to provide for the entity authorised to act on our behalf without power of attorney if it is also a legal entity, namely the Management Company?
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In this case, the same set of documents shall be submitted for the Management Company as for the legal entity which is the Holder, in accordance with the List posted on the website – Documents to be submitted to NSD (nsd.ru).

Except for: Form AA106, the Sample Signature and Seal Card of the Management Company, as well as Parts 2 and 3 of Form AA101 may be not completed.

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5. Is it possible to pre-check completed forms sent by e-mail?
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No, NSD does not provide services for preliminary verification of documents submitted by holders of Russian Federation Eurobonds. Holders need to submit a set of documents in the original. The verification will take 10 business days, and based on the results of the document verification, the application will be accepted or comments on any necessary modifications will be sent. After the modifications are made, the holder may submit additional documents, accompanying them with a Notification that These are Additional Documents (Information) to a Previously Submitted Application.

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6. What is a type-I account? Do I need it?
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A type-I account is an account opened by NSD in the name of foreign depositories for the purpose of fulfilling government debt obligations of the Russian Federation denominated in government securities with a nominal value in a foreign currency. You, as a holder, do not need to open a type-I account.

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7. How do I obtain approval from a foreign regulator to receive the payout?
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Upon acceptance of your Application for payout in foreign currency, NSD will notify you of the foreign depository where you should apply to receive the funds (Euroclear/Clearstream), and you may be required to obtain a foreign regulatory licence. We recommend that you seek legal advice to obtain a licence. NSD does not provide consulting services for obtaining a licence.

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8. How should fields 21-24 of the Application for Transfer of Proceeds on Eurobonds be filled in correctly?
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These fields should be filled in only if the restrictive measures are applied personally to the holder or if the holder is registered in the territory that is explicitly mentioned in the sanctions.

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9. Which documents may not be resubmitted to NSD if payout have already been received on the securities for which the documents were previously submitted?
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You do not need to resubmit identifying documents if there have been no changes since the previous set was submitted and if the application is marked accordingly.

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10. If I have not received approval for an application for rouble payment, can I provide details in any currency? If not, how do I know in which currency should be in details?
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No, you must provide bank details in a currency equal to the currency of the nominal value of the Russian Eurobonds in accordance with the prospectus.

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