--- title: "The Immobilization of Russian Securities on US Markets (2022-Present)" author: "DeepValues Research" publisher: "DeepValues Research (DeepValues / LuLu Ventures LLC)" type: "Research article" date: "2026-02-19" language: "en" section: "Market Vibes" answer: "DeepValues Research, “The Immobilization of Russian Securities on US Markets (2022-Present)” (Feb 19, 2026): The initiation of the full-scale invasion of Ukraine by Russia in February 2022 triggered an unprecedented regulatory and financial decoupling, fundamentally altering the status of Russian companies traded on US markets through American Depositary Receipts (ADRs)." canonical_url: "https://research.deepvalues.ai/market/russian-companies-us-market-status/" markdown_url: "https://research.deepvalues.ai/market/russian-companies-us-market-status/index.md" license: "CC BY 4.0" license_url: "https://creativecommons.org/licenses/by/4.0/" cite_as: "DeepValues Research, The Immobilization of Russian Securities on US Markets (2022-Present), https://research.deepvalues.ai/market/russian-companies-us-market-status/" publisher_url: "https://deepvalues.ai" app: "https://deepvalues.ai" api: "https://app.deepvalues.ai/developers" data_note: "Reports are dated snapshots. Current data via the DeepValues API: https://app.deepvalues.ai/developers" disclaimer: "Educational research, not investment advice." --- # The Immobilization of Russian Securities on US Markets (2022-Present) ## Executive Summary and Scope Confirmation The initiation of the full-scale invasion of Ukraine by Russia in February 2022 triggered an unprecedented regulatory and financial decoupling, fundamentally altering the status of Russian companies traded on US markets through American Depositary Receipts (ADRs). This report details the subsequent collapse of liquidity, the regulatory conflict between US sanctions and Russian counter-legislation, and the severe implications for US shareholders. The majority of Russian ADRs were subject to permanent suspension or delisting from US exchanges, including NASDAQ and NYSE, throughout 2022. This cascade was precipitated by Russian mandates, notably Federal Law No. 114-FZ, which forced the termination of the DR programs. For US investors, the asset value is now effectively **trapped and highly illiquid**. Even instances where conversions were successful led to the underlying Russian shares being placed in blocked "Type C" custody accounts within the Russian financial system. Critically, subsequent actions by the US Treasury's Office of Foreign Assets Control (OFAC) designated key Russian financial infrastructure, including the National Settlement Depository (NSD) and the Moscow Exchange (MOEX), as blocked entities, thus cementing these US-held positions as blocked assets subject to mandatory compliance and reporting. The corporate outcomes for US shareholders fall into three distinct models: - **Full Blocking (Sberbank):** Entities designated as Specially Designated Nationals (SDNs) are subject to a total asset freeze, rendering shares effectively irrecoverable through conventional market mechanisms. - **Forced Conversion/Trapped (Gazprom, Lukoil):** ADRs were cancelled and converted into illiquid Russian shares held in Type C accounts, inaccessible for repatriation by US investors. - **Corporate Restructuring (Yandex):** This represents a highly complex exception, where the Dutch parent company successfully divested its Russian operational assets to retain a non-sanctioned, internationally focused entity, offering a prospective, though still suspended, path to value recovery. ## The Immediate Financial Shock and Regulatory Decoupling (2022) ### The Delisting Cascade and Initial Market Freezing The geopolitical event of February 2022 led to an immediate, coordinated market response across Western jurisdictions. Trading halts were swiftly implemented on major US exchanges, including NASDAQ and NYSE, for Russian-affiliated securities. For example, Ozon Holdings PLC (OZON), a leading Russian e-commerce platform, saw its trading suspended on NASDAQ on February 28, 2022. These initial halts quickly escalated to permanent measures. The New York Stock Exchange (NYSE) and Nasdaq subsequently announced the definitive delisting of five Russian-affiliated companies. Parallel action was seen in Europe, where the London Stock Exchange (LSE) suspended trading in 27 firms with significant Russian exposure, including major companies such as Gazprom, Lukoil, and Sberbank. ### First-Order Sanctions and Financial Disruption The imposition of international sanctions was designed to inflict maximum damage on the Russian economy by freezing assets and severely limiting access to the global banking infrastructure. Key measures included the expulsion of several Russian banks from the SWIFT system and the restriction of payment networks like Mastercard and Visa. The cumulative impact of these first-order sanctions was a profound financial disruption. It created an inability to execute any transactions-whether purchases, sales, or transfers-for Russian securities held outside the Moscow Exchange (MOEX) framework, effectively freezing foreign holdings. ### Secondary Financial Risk of Suspension (Ozon Example) The market suspension introduced subtle yet critical secondary financial risks, extending beyond simple equity depreciation to impact corporate solvency and debt structures. The situation at Ozon Holdings PLC illustrates this complex interplay. The suspension of trading for Ozon ADSs on NASDAQ for a period exceeding seven dealing days constituted a "Delisting Event" under the terms and conditions of the company's $750 million convertible bonds due 2026. The occurrence of this event entitled bondholders to require the company to redeem their bonds at the principal amount plus accrued interest, or alternatively, to exercise conversion rights. This contractual trigger meant that the action of the US securities exchange in halting trading immediately translated into a significant contingent liquidity and solvency threat for the Russian issuer, demonstrating how market freezing introduced systemic financial risk to internationally listed companies with outstanding debt instruments. ## Regulatory Warfare: US Blocking vs. Russian Forced Conversion The current status of US-held Russian securities is defined by the head-on conflict between two fundamentally opposed legal and regulatory initiatives: Russia's drive to compel repatriation of underlying shares and the US strategy to block access to those assets. ### The Russian Delisting Mandate (FZ 114 and 319) The Russian Federation proactively initiated legislation aimed at decoupling the ownership of major Russian companies from foreign depositary systems. Federal Law No. 114-FZ, adopted in April 2022, prohibited Russian issuers from trading shares outside Russia via depositary receipts and mandated the termination of existing DR programs unless specific governmental approval was obtained. This law technically entitled DR holders to obtain the underlying shares of the Russian issuer. Subsequently, Federal Law No. 319-FZ (July 2022) introduced an alternative mechanism known as "Mandatory Conversion." This provision allowed holders, including foreign investors, to apply for conversion of their ADRs directly into Russian shares through a Russian custodian, explicitly bypassing the foreign depositary banks and clearing systems that had become entangled in sanctions. Although this procedure offered a theoretical path to ownership of the underlying assets, the deadline for Mandatory Conversion applications expired in November 2022, leaving many investors unable to comply due to logistical and procedural difficulties. ### US Counter-Sanctions: Full Blocking and Infrastructure Targeting The US regulatory response, orchestrated by OFAC, was designed to systematically immobilize assets by sanctioning the core financial conduits necessary for transactions to settle. A significant early measure was the imposition of full blocking sanctions, such as the designation of Public Joint Stock Company Sberbank of Russia, one of Russia's largest banks, as an SDN in April 2022. This SDN classification legally prohibits US persons from engaging in any direct or indirect dealings with Sberbank or its property, effectively eliminating any market-based recovery for its ADR holders. The blockade was expanded significantly in June 2024 with the designation of the three central components of Russia's securities market infrastructure as SDNs: the Moscow Exchange (MOEX), the National Clearing Center (NCC), and the National Settlement Depository (NSD), Russia's central securities depository. This blocking action, which followed the European Union's earlier sanctioning of the NSD in June 2022 , severely restricts activities such as the sale of local Russian securities traded on MOEX and necessitates a specific OFAC license for any transaction involving securities held through the NSD. ### The Perfect Financial Blockade The sequencing of sanctions and counter-legislation resulted in a highly effective financial blockade specifically designed to trap assets. Russia's mandated conversions required the involvement of intermediary systems (such as Clearstream and Citibank). Once the EU sanctioned the NSD, clearing houses like Clearstream stopped processing conversions, trapping residual value. This trapped value, often registered with the NSD, became the target of US blocking sanctions in 2024. This dual-sided regulatory environment ensured that even US investors who successfully navigated the logistical complexities of conversion ultimately found their underlying shares instantly illiquid and legally designated as blocked property under US law. This outcome demonstrates that the US strategy prioritized immobilizing the assets within the Russian system, regardless of technical ownership status, making any conventional recovery unfeasible. ## Conversion Mechanics: The Process of Trapping Value The process of converting ADRs into underlying Russian shares proved to be a critical, yet ultimately futile, step for most US investors, leading directly to asset immobilization within the Russian capital control apparatus. ### Conversion Procedures and Impediments Investors faced significant obstacles when attempting to convert their ADRs, whether through the Standard or Mandatory Conversion procedures. Successfully executing a conversion generally required opening a depositary or brokerage account with a Russian entity that maintained an account with the NSD. However, US sanctions prohibit US citizens from initiating new depositary relationships with Russian financial institutions. The Mandatory Conversion procedure, intended by Russia to circumvent foreign agents, was fraught with procedural complexity. Obstacles included tight statutory deadlines, stringent documentary requirements, and a high degree of discretion exercised by Russian custodians when assessing eligibility. Furthermore, while certain depositary banks, such as Citibank N.A. for Lukoil, offered limited windows for cancellations and conversions in 2023 and 2024 , these actions were strictly constrained by OFAC General Licenses (such as GL 100a), which permitted conversions into NSD only until their expiry date in October 2024. ### The Type C Account Regime The successful conversion of ADRs resulted in the placement of the underlying shares into a specialized, restrictive account structure known as "Type C" accounts, mandated by the Russian Federation for assets held by investors from "unfriendly jurisdictions". These jurisdictions include the US, the EU, and the UK. While investors technically possess ownership rights to the underlying shares (e.g., Gazprom, MTS) , trading them is heavily restricted, making them entirely illiquid. Furthermore, although dividends may continue to be declared and paid by the Russian issuers, these funds are credited solely to the blocked Type C bank accounts and cannot be repatriated or accessed by the US shareholder. ### Russian Retaliation: The NSD Workaround and OFAC Counter In response to the US blocking sanctions imposed on the NSD in June 2024, Russia introduced Presidential Decree No. 840 in October 2024. This decree ordered Russian custodians to transfer shares held in Type C accounts *away* from the sanctioned NSD and directly to the local registrars of the joint-stock companies. This move was clearly intended to shield Russian securities from sanctions tied to the NSD's involvement. However, the efficacy of this workaround was immediately neutralized by the US. OFAC issued FAQ 1197 in November 2024, explicitly stating that US persons must continue to treat these Russian shares as **blocked assets**, irrespective of whether they are held at the NSD or subsequently transferred to local registrars under Decree 840. OFAC warned that transfers made pursuant to Presidential Decree 840 "may be considered null and void". This regulatory determination confirms that the blocking status of these assets is based on the US holder's jurisdiction and the nature of the Russian regulatory action, not merely the specific custodian location. ## Focused Corporate Case Studies and Outcomes The outcome for US shareholders is highly differentiated based on the corporate characteristics of the issuer, particularly their ties to the Russian state and their legal domicile. ### Case Study 1: Fully Blocked Entities (Sberbank, Gazprom) Sberbank (SBRCY), as a major state bank, represents the most severe outcome. Its designation as an SDN in April 2022 placed it under full blocking sanctions. This designation prohibits US persons from all dealings with the bank's shares. While depositary banks offered limited wind-down options for cancellation , any converted Sberbank shares remain frozen in segregated accounts. Due to the full blocking status, the exchange of Sberbank ADRs is deemed impossible by some legal experts. Gazprom (OGZPY), the state energy monopoly, also had its ADR program cancelled. Though not designated as an SDN, converted Gazprom shares are subjected to the limitations of the Type C account regime, where trading is restricted and dividends are blocked from repatriation. ### Case Study 2: Energy/Commodity Firms (Lukoil) Lukoil (LUKOY) successfully terminated its depositary receipt programs. The depositary bank, Citibank N.A., re-opened conversion books, allowing US holders to convert their ADRs into local shares (LKOH.ME) until the October 2024 deadline. However, this technical success did not equate to recovery. The resulting underlying shares remain governed by the Type C regime, ensuring their illiquidity and the trapping of any associated income. ### Case Study 3: The Restructuring Exit (Yandex N.V.) Yandex N.V. (YNDX), domiciled in the Netherlands, pursued a strategic restructuring to separate its international businesses from its core, Russia-based operations. This separation was critical, as the Dutch domicile allowed Yandex to pursue a corporate action aimed at compliance with Western demands. In 2024, YNV completed the sale of its Russian assets to a consortium for approximately $5.4 billion (RUB 475 billion). This transaction, however, was negotiated under strict Kremlin rules that mandated a substantial discount (estimated at 50%) on the value of foreign assets being sold. The consideration was a mix of cash ($2.8 billion) and YNV Class A shares. The remaining entity, renamed Nebius Group, retains the non-sanctioned, international businesses. The YNV Class A shares received as consideration were moved to treasury. Although trading in YNV shares remains halted on NASDAQ , this corporate divorce successfully insulated the remaining holding company from the Russian financial infrastructure. This scenario represents the most promising outcome for shareholders, as the underlying asset is no longer subject to the SDN blocking or Type C account constraints, positioning it for potential re-liquefaction when the NASDAQ trading halt is lifted. | **Company (US Ticker)** | **Sector** | **ADR Status (NASDAQ/NYSE)** | **Underlying Asset Status** | **US Shareholder Outcome Model** | |-------------------------|------------|------------------------------|----------------------------------------------------------------------------|------------------------------------------------| | Sberbank (SBRCY) | Financials | Delisted/Program Cancelled | Fully blocked, SDN designated. Shares held in frozen accounts. | Fully Blocked/Irrecoverable via standard means | | Gazprom (OGZPY) | Energy | Delisted/Program Cancelled | Converted shares held in blocked Type C accounts. | Forced Conversion/Trapped Value | | Lukoil (LUKOY) | Energy | Delisted/Program Cancelled | Conversion possible during specific windows; resulting shares in Type C. | Forced Conversion/Trapped Value | | Yandex N.V. (YNDX) | Technology | Suspended (NASDAQ) | Russian assets divested; residual entity (Nebius Group) is non-sanctioned. | Corporate Restructuring/Potential Recovery | ## Financial and Legal Implications for US Shareholders ### Liquidity, Valuation, and Income Blockage For US persons, the market value of these converted securities is purely theoretical, as zero marketability exists. Trading is restricted to the Moscow Stock Exchange, requiring depositary accounts in Russia, which US sanctions explicitly prohibit US citizens from opening. The subsequent SDN designation of MOEX and NSD reinforces this market closure, restricting any secondary market divestment attempts that rely on this infrastructure. Furthermore, while Russian companies continue to pay dividends, these cash flows are systematically blocked. Dividends on converted shares are credited solely to the blocked "Type C" bank accounts established for "unfriendly" investors, preventing any repatriation or access by the US shareholder. The consequence of this regulatory landscape is that the holding of these securities has shifted from a financial investment to an active legal and compliance liability. The inability to transact, coupled with blocked income, means the shareholder's involvement is dictated entirely by US government reporting requirements (OFAC) and tax protocols (IRS), rather than market function. ### The OFAC Compliance Burden The status of these holdings as blocked property imposes an ongoing compliance burden on US persons. OFAC FAQ 1197 mandates that following the expiration of general licenses, any securities held by US persons that are related to the NSD, or that have been transferred pursuant to Russian Decree 840, must be treated as **blocked**. This requires US persons to file initial blocking reports and Annual Reports of Blocked Property to OFAC, effectively obligating the investor to formally track and report the immobilized asset to the US government. ### Tax Treatment of Worthless Securities Given the financial immobilization, the primary mechanism for US investors to recover capital is through claiming a tax loss. Section 165(g) of the Internal Revenue Code allows a capital loss deduction for securities that become worthless during the tax year. The loss is treated as if the security was sold for zero value on the last day of the year in which worthlessness occurred. To manage the legal ambiguity surrounding the precise date of worthlessness, some US taxpayers may formally abandon the securities by permanently surrendering all rights. This preemptively locks in the loss in the desired tax year and protects against an IRS challenge arguing the security became worthless in an earlier period. Finally, any future divestment attempts will be complicated by Russia's potential imposition of "exit taxes," which OFAC currently deems prohibited transactions requiring specific licensing, as they involve Directive 4 entities (such as the Ministry of Finance). ## Forecasting the Post-War Recovery Landscape The resumption of liquidity for US-held Russian securities is entirely conditional on complex political agreements surrounding sanctions and asset seizures. The fate of private capital is inextricably linked to the status of frozen Russian sovereign assets. ### Prerequisites for Re-Liquefaction The restoration of market function requires the reciprocal dismantling of restrictive regimes: 1. **US Sanctions Relief:** OFAC must revoke the SDN designations on key financial infrastructure (NSD, NCC, MOEX) and major banks (Sberbank), or issue comprehensive General Licenses authorizing transactions involving Type C accounts. 2. **Russian Capital Control Removal:** Russia must repeal or fundamentally alter Federal Laws 114-FZ and 319-FZ, and, critically, lift the restrictions preventing foreign investors from selling or repatriating capital from the Type C account regime. Should liquidity return, market analysis suggests that the immediate valuation of Russian equities would be significantly suppressed due to the anticipated mass withdrawal of capital by investors who have been trapped for years. ### The Compensation/Seizure Nexus The single greatest long-term risk to US private assets is the international debate concerning the utilization of the estimated $300 billion in frozen Russian sovereign assets for Ukrainian reconstruction. While the US has authorized the President to seize the $3 billion to $4 billion of Russian sovereign assets held in US institutions , this action carries severe counter-retaliation risk. Russia has established a mechanism via Presidential Decree that allows Russian courts to seize US private and state assets-including securities and shares held by US persons-as compensation for Russian losses resulting from Western asset seizures. This dynamic places the private investor in a precarious position. If Western governments proceed with the confiscation of sovereign assets, Russia is highly likely to retaliate by forfeiting the converted shares held by US investors in Type C accounts, which serve as the legal inventory for this counter-seizure. Thus, the recovery of US private capital is strategically subordinate to the geopolitical decision concerning state reparations. ### Investor Recovery Scenarios The path forward is highly speculative, with three potential scenarios emerging: - **Scenario A: Diplomatic Resolution:** A comprehensive peace settlement includes the negotiated removal of sanctions and capital controls. Liquidity returns, permitting the sale of Type C shares. This scenario is highly sensitive to price depression resulting from simultaneous mass divestment. - **Scenario B: Protracted Legal Battles:** Absent a geopolitical resolution, investors may pursue legal remedies, such as litigation against depositary banks or brokers, although these claims face immense jurisdictional and legal barriers due to the supremacy of government-mandated sanctions. - **Scenario C: State Compensation/Fund Creation:** Should Russia confiscate the Type C assets in retaliation for sovereign asset seizure, the US government may face pressure to establish a compensation fund for private investors. This fund could potentially be financed using the interest or proceeds generated from the frozen Russian sovereign assets. However, the current legislative focus is primarily directed toward using sovereign assets for Ukrainian reconstruction , making direct compensation for private losses a non-mandated and legally complex proposition. | **Issuing Authority** | **Instrument (Law/Sanction/Decree)** | **Key Action and Investor Impact** | |-----------------------|----------------------------------------|-----------------------------------------------------------------------------------------------------------------------| | Russian Federation | Federal Law No. 114-FZ (Delisting Law) | Mandated termination/delisting of DR programs; forced conversion of ADRs to underlying shares. | | Russian Federation | Type C Accounts Regime | Restricted ownership, blocking of assets, and trapping of dividends for "unfriendly jurisdictions." | | US Treasury (OFAC) | SDN Designation on Sberbank (SBRCY) | Full asset blocking, rendering Sberbank ADRs/shares irrecoverable for US persons. | | US Treasury (OFAC) | Blocking of MOEX/NCC/NSD | Asset freezing of Russia's core financial infrastructure, severely restricting all divestment attempts by US persons. | | US Treasury (OFAC) | FAQ 1197 | Confirmed that shares transferred under Decree 840 remain blocked and subject to US reporting requirements. | #### Works cited 1\. 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