Payment of proceeds on Russian Eurobonds

The information below is relevant to individual and corporate investors, as well as Russian depositories with clients holding Eurobonds.

Due to the current restrictions on payments by foreign counterparties, the Ministry of Finance of the Russian Federation has defined a new procedure for payouts from government securities with nominal value denominated in foreign currency ("Russian Federation Eurobonds"). The new procedure is established by the Decree of the President of the Russian Federation dated 09 September 2023 N 665 "On the Temporary Procedure for the Execution to Residents and Foreign Lenders of Russian Government Obligations in Government Securities, Denominated in Foreign Currency, and Other Obligations under International Securities" (the "Decree 665"). 

The previously effective Decree of the President of the Russian Federation N 394 dated 22 June 2022 has become invalid (the "Decree 394").

The procedure for making payouts for the clients of the central securities depository and Russian securities depositories with which Eurobonds of the Russian Federation are held on accounts, including accounts for third party rights, with international depositories and which have provided the CSD with information on such Eurobonds within the period specified in the request of the CSD, remains unchanged as compared to the procedure which was established by Decree 394.

Payouts to beneficiaries of type I bank account, i.e. holders of  Eurobonds of the Russian Federation whose rights are held in international depositories, and Russian depositories with which Eurobonds of the Russian Federation are held on accounts, including accounts for third party rights, in international depositories and which have NOT provided the CSD with information on such Eurobonds within the term specified in the CSD's request, are made according to the new algorithm established by Decree 665.

Payouts from Eurobonds of the Russian Federation, which have been credited by the CSD to type I bank accounts up to and including 15 September 2023, are subject to the following conditions:

  • Payouts are made by the CSD until 24 November 2023 inclusive to holders of  Eurobonds of the Russian Federation added to the register of holders of Russian Federation Eurobonds before 23 November 2023 and to Russian depositories that provided the CSD at its request the total number of  Eurobonds of the Russian Federation after the expiry of the term set by the CSD, in RUB in the amount calculated as of the date of their transfer to the holder in accordance with the indexation procedure established by Paragraph 1-d of Decree 365.
  • From 25 November to 14 December 2023, cash amounts are not indexed, no payouts are made from the above accounts;
  • On 14 December 2023, the obligations of the CSD to make payouts in RUB from type I accounts are to be replaced by the CSD's obligations to make payouts in other currency. The procedure for replacing the obligations is established by the Ministry of Finance of the Russian Federation. From 15 December 2023, the payouts are made in foreign currency in accordance with Paragraph 7 of Decree 665.

PRINCIPLES OF DISTRIBUTION FOR EUROBONDS OF THE RUSSIAN FEDERATION DEPOSITED ON TYPE I ACCOUNTS BEFORE 15 SEPTEMBER 2023

Payouts from Eurobonds of the Russian Federation, which have been credited to the CSDs to type I accounts after 16 September 2023, are subject to the following conditions:

  • Payouts are made on the 91st day after the date of the regular payout in RUB in the amount calculated on the date of payment in accordance with the indexation procedure established on the basis of Paragraph 1-f of Decree 665, to holders of  Eurobonds of the Russian Federation who have provided the CSD with supporting documents within 60 days after the date of the regular payout on the Eurobonds and have been added by the CSD to the register of holders of the Eurobonds within 90 days after the date of the regular payout, and to Russian depositories that provided the CSD at its request with the total number of the Eurobonds, after the expiry of the term set by the CSD (paragraph 9-a of Decree 665).
  • Indexation shall be made at the exchange rate set by the Central Bank of the Russian Federation on the 91st day after the date of the regular payout from the Eurobonds of the Russian Federation as defined in the prospectus. The procedure for such indexation is established by the Ministry of Finance of the Russian Federation in coordination with the Central Bank of the Russian Federation (paragraph 1-f of Decree 665);
  • On the 91st after the regular payout, the obligations of the CSD to make payouts in RUB from type I accounts are to be replaced by the CSD's obligations to make payouts in other currency. The procedure for replacing the obligations is established by the Ministry of Finance of the Russian Federation (paragraph 9-b of Decree 665). Further, payments to persons who are beneficiaries with respect to the type I bank account to whom payouts have not been made on the 91st day, as indicated above, are made in foreign currency using funds on the accounts of the CSD in international depositories.

PAYOUT RULES FOR E UROBONDS OF THE RUSSIAN FEDERATION DEPOSITED ON TYPE I ACCOUNTS AFTER 16 SEPTEMBER 2023

Please note: You can determine the chain of custody of your securities by contacting the broker through which they were purchased or the depository with which you have a depository agreement to hold them.

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Procedure to receive income
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Step 1 – the security you hold is on the list of distributions

If you have invested in Russian Federation Eurobonds, you first need to find out whether the security for which you wish to receive payout is on the list of securities for which NSD makes payouts.

If you held Russian Federation Eurobonds on the date indicated on the list, the payment will be made in accordance with the new procedure established by Russian Presidential Decree No. 665 of 09 September 2023 (the "Decree").

Please note that holders of Russian Federation Eurobonds and persons exercising rights under such securities are recorded either at the end of the third business day prior to the payment date or earlier in accordance with the procedure set forth in the issue documents.

If you held Eurobonds but the due date was earlier than 22 June 2022, the payouts are not shown in the list as they are not covered by the Decree. The Russian Federation Eurobonds have been redeemed in accordance with the procedure set out in the documentation accompanying the relevant securities issues and you should contact your depository/broker for clarification.

If you cannot find the payout on the list and the due date has not yet arrived, you should wait for the date and check the list again.

Step 2 – Check the chain of custody of your securities

Next, you need to check whether there is a Russian depository in the chain of custody for your securities.

This information can be obtained from the broker through which the securities were purchased or from your depository.

  1. If your Eurobonds are recorded with NSD or with a Russian securities depository which has an account with an international depository to record rights to Eurobonds, funds in roubles will be delivered to you in the manner prescribed by Article 8.7 of Federal Law No. 39-FZ of 22 April 1996 "On the Securities Market", i.e. by so-called "cascading payments".

    If you are an investor in this group, you will still receive payments in RUB as before. You do not need to provide NSD with any application or additional forms and steps 3-7 are not applicable. You can keep track of your receipts as before, for example in your brokerage account.

    Payments will be made in RUB at the rate set by the Bank of Russia on the payment date stipulated in the bond issue documents.

    If you have not received the payout from the depository by the due date, you should contact it for further details.

  2. If your Eurobonds are held with an international securities depository without any Russian depository involved, you need to have your title to the security confirmed in order to receive the payout. NSD is the paying agent for these securities, so you will need to submit an application and the necessary documents to NSD in order to receive income payment.

    Until title is confirmed, funds will be deposited by NSD into a special account (type I account) from which they will be paid to you.
    • If you have applied for a payout that took place before 15 September 2023, on or before 07 November 2023, and your application was approved before 21 November 2023, the funds in the said account will be indexed at the current market exchange rate of the notional currency until the actual settlement with the holders. The payout is made in roubles;
    • If you applied for a payout that took place before 15 September 2023, after 07 November 2023, and your application was approved, then the payment will be made after 15 December 2023 out of the funds in the foreign currency in which the obligations under the  Eurobonds of the Russian Federation are denominated, held on NSD's accounts with an international depository;
    • If you apply for a payout that took place after and including 16 September 2023, within 60 days after the regular payout, and your application is approved by the 90th day after the payment date, such payout will be made on the 91st day after the payment date in roubles at the exchange rate on the date of such payment;
    • If you have applied for a payout made after 16 September 2023, inclusive, 60 days after the regular payout date, and your application has been approved, the payout will be made out of the funds in foreign currency in which obligations under the Russian Eurobond are denominated, held on NSD's accounts with an international depository;

      For more details on the payout scheme, please refer to the General Information section.

Payout procedures and indexation are determined by the Decree and the Ministry of Finance.

Step 3 – Clarify whether there has been an international depository disclosure

Under the new payment procedure, NSD sends requests to international securities depositories to obtain names of Eurobond holders. Contact your broker or depository and find out whether the international depository has provided information on you upon NSD's request. This will determine whether you will need to provide NSD with a full set of documents or a shortened set in order to receive income payments.

Important note: in practice, such disclosure is very rare nowadays.

Step 4 – Submit an online request using the form on NSD's website

To facilitate communication on Eurobond payouts, please complete and submit an online request on NSD's website. This way, we can check whether there has been a disclosure by the international depository and send you a complete list of documents that you will need specifically. Please complete all fields in the form, including ISIN of the security and the record date. We recommend that the details of the holder should be specified in the same way as in the international depository.

Please note: an online request and/or original documents must be submitted after the record date applicable to the relevant payout, as proof of Eurobond ownership is required at the record date. Any requests submitted prior the record date will automatically be rejected.

Step 5 – Prepare documents to submit to NSD

The full List of documents to be submitted to NSD by holders of Russian Federation Eurobonds (in cases where the International Depository has/has not made the List of Holders available) is available on the NSD website.

  • If you have submitted the request through the online form on the website, we will send you a list of documents that you need to submit by return email.
  • If you have not applied through the form, please use the list of documents below.
  1. Partial set of documents (the international depository provides information at NSD's request)
  2. Complete set of documents (the international depository does not provide information at NSD's request)

Please note that there is currently no statutory deadline for submitting documents to receive payouts on Russian Federation Eurobonds. But the currency and payment arrangements will depend on when you apply.

Step 6 – Submit original documents to NSD

Original documents may be delivered to NSD in person to the address: 12 Spartakovskaya St., Moscow (entrance from Pleteshkovkiy Lane), by Russian Post or other telecom operators.

Documents are accepted at the office:

  • MON-FRI 10:00 – 15:00 (break: 13:00 – 13:45)

Documents are accepted by appointment. Appointment can be made using the online form on NSD's website. If there is no appointment, documents will be accepted on a first-come, first-served basis.

Please note: an online request for payout and/or original documents must be submitted after the record date applicable to the relevant payout, as proof of Eurobond ownership is required at the record date. Any requests submitted prior the record date will automatically be rejected.

Step 7 – Wait for completion of verification and income payout

Verification of documents takes up to 10 business days from the receipt of a complete set of documents.

Payouts in RUB (see paragraph 2, Step 2)

If the documents are approved, NSD will make payments in roubles within 3 business days at the rate set by the Bank of Russia on the date of crediting the funds.

If the international depository provides NSD with information on you and the Eurobonds held by you the payment will be sent to your bank account specified in the international depository's disclosure.

If the international depository does not provide NSD with information on you and the Eurobonds held by you, payment will be sent to your account as you specify in your income payout application. Only rouble account in your name are accepted for making payments.

Payouts in other currency (see paragraph 2, Step 2)

If the documents are accepted, but the payout is a foreign currency, you will need to apply for funds to an international depository, which will be notified to you by NSD. You may need to obtain a licence from a foreign regulator.

Important note: NSD's obligations to make a payout in foreign currency are deemed to be duly fulfilled from the moment the CSD submits to the international depository by the means available to it an instruction to transfer funds in foreign currency from its account with the depository in favour of the holder of the Russian Federation Eurobonds.

Step 8 – Applying for the second time

After Order 285 of the Ministry of Finance of the Russian Federation dated 23 June 2023 "On Amendments to the List of Documents Confirming the Rights of Holders of Russian Government Securities Denominated in Foreign Currency" approved by Order of the Ministry of Finance of the Russian Federation No. 245 dated 24 June 2022 "On Approval of the List of Documents Confirming the Rights of Holders of Russian Government Securities Denominated in Foreign Currency", you may submit an Application once again for review of the documents for which NSD denied the payout. In this case, please mark in box 22 of the Application Form that the documents have already been submitted to NSD earlier.

Before submitting the Application, please make sure that the documents you have previously submitted meet NSD's requirements for their completeness.

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Forms to receive income
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  • If you have applied for income payout through the online form on the website, we will send you a list of documents that you have to submit by return email.
  • If you have not applied through the form, please use the list of documents below.

To receive income payments, please submit the documents as specified above to NSD.

Original documents may be delivered to NSD in person to the address: 12 Spartakovskaya St., Moscow, 105066 (entrance from Pleteshkovkiy Lane) or by Russian Post or other telecom operators.

Documents are accepted at the office:

  • MON-FRI 10:00 – 15:00 (break: 13:00 – 13:45)

Document review takes up to 10 business days, and if after its completion NSD has no doubts about the sufficiency of the documents, NSD will make payments in Russian roubles within 3 business days.

If the international depository provides NSD with information on you and the Eurobonds held by you the payment will be sent to your bank account specified in the international depository's disclosure in an amount equivalent to the amount due for payment in the currency of the Eurobond face value on the date of crediting.

If the international depository does not provide NSD with information on you and the Eurobonds held by you, payment will be sent to your account as you specify in your income payout application in an amount equivalent to the amount due for payment in the currency of the Eurobond face value on the date of crediting. Payments can only be made to a personal rouble-denominated account, so if you don't have one, you will need to open one.

However, until title is confirmed, funds will be deposited by NSD into a special ruble account (type "I" account) from which they will be paid to you. Funds in the said account will be indexed at the current market exchange rate for the nominal currency until actual settlement with the owners.

Payments from the special indexed account will be made as the full set of documents for payment is received and the holder is included in the Register in accordance with paragraph 2d) of Order No. 2445 of the Ministry of Finance of Russia dated June 24, 2022 based on this package.

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  • If you have applied for income payout through the online form on the website, we will send you a list of documents that you have to submit by return email.
  • If you have not applied through the form, please use the list of documents below.

To receive income payments, please submit the documents as specified above to NSD.

Original documents may be delivered to NSD in person to the address: 12 Spartakovskaya St., Moscow, 105066 (entrance from Pleteshkovkiy Lane) or by Russian Post or other telecom operators.

Documents are accepted at the office:

  • MON-FRI 10:00 – 15:00 (break: 13:00 – 13:45)

Document review takes up to 10 business days, and if after its completion NSD has no doubts about the sufficiency of the documents, NSD will make payments in Russian roubles within 3 business days.

If the international depository provides NSD with information on you and the Eurobonds held by you the payment will be sent to your bank account specified in the international depository's disclosure in an amount equivalent to the amount due for payment in the currency of the Eurobond face value on the date of crediting.

If the international depository does not provide NSD with information on you and the Eurobonds held by you, payment will be sent to your account as you specify in your income payout application in an amount equivalent to the amount due for payment in the currency of the Eurobond face value on the date of crediting. Payments can only be made to a personal rouble-denominated account, so if you don't have one, you will need to open one.

However, until title is confirmed, funds will be deposited by NSD into a special ruble account (type "I" account) from which they will be paid to you. Funds in the said account will be indexed at the current market exchange rate for the nominal currency until actual settlement with the owners.

Payments from the special indexed account will be made as the full set of documents for payment is received and the holder is included in the Register in accordance with paragraph 2d) of Order No. 2445 of the Ministry of Finance of Russia dated June 24, 2022 based on this package.

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If you have opened a nominee account with NSD to record your rights to Eurobonds

In this case proceeds to be paid to Eurobond holders will be delivered to you in accordance with the procedure set forth in Article 8.7 of Federal Law No. 39-FZ of 22 April 1996 "On the Securities Market", i.e. in the so-called "cascade payments".

In essence, this means that payments will be received as before. You will receive the amount in RUB to be paid out to investors. No documents or applications need to be submitted to NSD by you or your clients holding Eurobonds.

If you have opened an account with an international securities depository to record your rights to Eurobonds

In this case, to receive cash payment proceeds to be paid out to Eurobond holders, you will need to respond within the timeframe set by NSD to a request to disclose the total number of Eurobonds held in your accounts with the international depository.

  • NSD participants and clients who are not NSD participants will receive a request on Form CA311 (Corporate Action Notice) via electronic communication channels (CA Web Desk and WEB service).
  • The participant shall reply with the instruction in CA333 format (Universal Instruction). Information on how to complete will be given in the Corporate Action Notice.
  • Russian securities depositories which are not clients of NSD will receive a request to their official addresses. The procedure for disclosure will be specified in the request.

If open accounts with an international depository was not timely disclosed to keep records of title for Eurobonds

In this case, you will need to submit a new disclosure with the following information to NSD in order to receive funds for payouts to holders of Eurobonds:

  • Total number of Russian Federation Eurobonds held by Russian depositories on the accounts of the Russian depository in an international depository and/or accounts of the owner of the Russian depository, which was not disclosed earlier. This is provided as an instruction in CA333 (Universal Instruction) format. Information on how to complete is given in the Corporate Action Notice;
  • Eurobond Custody Scheme which keeps details of all international securities depositories and/or international brokers, as well as Russian Depositories involved in keeping records of the rights to the Eurobonds (the scheme may be specified in the CA333 format instruction);
  • Information provided by a Russian depository to which a Russian depository account is opened with an international securities depository or an account of the Russian depository owner and which has not reported the total number of Eurobonds of the Russian Federation to the central depository upon its request, indicating that information on the number of the Eurobonds has not been provided by such depository upon the central depository's request;
  • This information shall be provided in the form of a Letter sent to NSD via NSD's EDI (client depository code NDC000ORK000) or in hard copy.

Payouts made before 15 September 2023 need all documents be submitted by 10 November 2023 in order to receive them in roubles.

Verification of documents takes up to 10 business days from the receipt of a complete set of documents. If the documents are approved, NSD will make payments in roubles within 3 business days at the rate set by the Bank of Russia on the date of crediting the funds.

For payouts made after 16 September 2023 inclusive, all documents must be submitted no later than 89 days after the date of the relevant payout in order to receive the amount in roubles on the 91st day after the date of the relevant payout.

If the above deadlines are not met, only the holder of Russian Federation Eurobonds will be able to receive the amount in foreign currency in accordance with the procedure described in the section Holders of Securities

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Procedure for providing the list of holders of Russian Federation Eurobonds and other persons exercising rights on Russian Federation Eurobonds by international securities depositories

This procedure has been set out to implement Decree of the President of the Russian Federation No. 665 dated 9 September 2023 "On the Temporary Procedure for the Settlement to Residents and Foreign Lenders of Russian Government Obligations in Government Securities, Denominated in Foreign Currency, and Other Obligations under International Securities" (the "Decree 665")

NSD sends a request with respect to the securities in the Attachment, for the List to international securities depositories performing ICSD functions (Euroclear Bank S.A./N.V. / Clearstream Banking S.A. / Depository Trust Company), as well as to foreign nominee holders having an account with NSD.

Such request shall be sent on the day following the record date in accordance with the issue documentation.

International securities depositories that do not have accounts at NSD for Russian Federation Eurobonds
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  1. The request to collect the list is sent to international securities depositories in the form of a letter to the e-mail addresses known to NSD, as well as by regular mail.
  2. An international securities depository may provide NSD with the list in response to the request. The list must be provided by an authorised person of the ICSD in the form of an Excel file filled in according to the prescribed template as of the record date for the payout under Russian Federation Eurobonds.
  3. The completed file in Excel format must be titled as follows: "BO DCSL MF __ ".
  4. The list should be provided using SWIFT FileAct service for BIC MICURUMM. The message identifiers shall be as follows:
    • Message ID: seev.xxx.nsd.xls.rf005
    • Request Type: seev.xxx.nsd.xls.rf005
  5. Notification of the List sent must be submitted to NSD by email to .

By sending the List to NSD, ICSD warrants that, if "YES" is completed in the field for written waivers of all potential future claims, written waivers in a form prescribed by NSD from any person on the List will be provided to NSD upon NSD's request. A Holder may also submit a written waiver directly to NSD.

Furthermore, a Holder of Eurobonds should send documents for calculating and withholding taxes in respect of payments directly to NSD in accordance with the procedure set out in the Holders of Securities section.

Please note the following points:

  • Disclosures received will be processed on an ongoing basis, no deadline for providing disclosures has been set at this time. If the disclosure form is filled out incorrectly, NSD will send comments. ICSD may resubmit the disclosure.
  • In case of disclosure in respect to the payout made before 15 September 2023, before 7 November 2023 and approval of the payout before 21 November 2023, the funds on type I account will be indexed at the official foreign currency exchange rate set by the Central Bank of the Russian Federation on the Payment Date, with an allowable deviation of 15 kopecks. The payout is made in roubles.
  • In case of disclosure in respect to the payout made before 15 September 2023, after 7 November 2023 and approval of the payout, the payment will be made after 15 December 2023 out of the funds in the foreign currency in which the Russian Federation's Eurobond obligations are denominated, held on NSD's accounts with the international securities depository.
  • In case of disclosure in respect to the payout made after and including 16 September 2023 within 60 days after the regular payment date specified in the prospectus and the payout is approved before the 90th day after the regular payment date specified in the prospectus, the funds will be transferred on the 91st day in roubles at the exchange rate of the foreign currency in which the obligations under the Russian Federation Eurobonds are denominated on the date of such payment.
  • In case of disclosure in respect to the payout made after and including 16 September 2023 within 60 days after the regular payment date specified in the prospectus and the payout is approved, the funds will be transferred out of the funds in the foreign currency in which the Russian Federation's Eurobond obligations are denominated, held on NSD's accounts with the international securities depository;
  • The Ministry of Finance of the Russian Federation settles its obligations under the Russian Eurobonds through NSD in accordance with the procedure described in the Overview section.
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Foreign nominee holders that have accounts at NSD for Russian Federation Eurobonds
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  1. The request to form the list is sent to foreign nominee holders in the form of a regular request in Form GS61N.
  2. The list is provided by submitting a request in Form RF005 (an electronic message in the format FCDR_2017_02, REGISTER_OF_SHAREHOLDERS_V02 "List/Information about holders"). The tag "Additional information on the person exercising rights under the securities" in the REGISTER_OF_SHAREHOLDERS_V02 message must contain information on whether the Eurobond holder has a written waiver of all possible future claims. The procedure for completing this field is set out in NSD's request. 

By sending the List to NSD, the foreign nominee holder warrants that, if "YES" is completed in the field for written waivers of all potential future claims, written waivers in a form prescribed by NSD from any person on the List will be provided to NSD upon NSD's request. The holder may also submit a written waiver directly to NSD.

If the disclosure form is filled out incorrectly, NSD will send comments. The foreign nominee holder may resubmit the disclosure.

Please note the following points:

  • The list with the type "0012 - Basic with bank details of persons exercising rights under the securities" is accepted by NSD until 07 November 2023 for the payout made before 15 September 2023. In this case, if the payout for this list is approved before 21 November 2023, the funds on type I account will be indexed at the official foreign currency exchange rate set by the Central Bank of the Russian Federation on the Payment Date, with an allowable deviation of 15 kopecks. The payout is made in roubles.
  • After 7 November 2023, NSD will send a new request regarding the payout made before 15 September 2023 to collect the List with the type "0010 - Basic with currency details". In this case, payout to the approved Holders will be made after 15 December 2023 out of funds in the foreign currency in which the Russian Federation's Eurobond obligations are denominated, held on NSD's accounts with an international securities depository.
  • For payouts made after and including 16 September 2023, within 60 days after the regular payment date specified in the prospectus, NSD will accept a List with the type "0012 - Basic with bank details of persons exercising rights under the securities". If the payout pertaining this disclosure is approved before the 90th day after the regular payment date specified in the prospectus, it will be made in roubles at the exchange rate of the foreign currency in which the Russian Federation Eurobonds are denominated as at the date of the payment.
  • 60 days after the regular payment date specified in the prospectus, NSD will send a new request regarding the payout made after 16 September 2023 to collect the List with the type "0010 - Basic with currency details" If the List for this payout is provided 60 days after the regular payment date, and the payout is approved, the payout will be made out of the funds in foreign currency in which obligations under the Russian Eurobond are denominated, held on NSD's accounts with an international securities depository.
  • The Ministry of Finance of the Russian Federation settles its obligations under the Russian Eurobonds through NSD in accordance with the procedure described in the Overview section.
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