Russia: Related sanctions


Further to announcement A22130, Clearstream Banking now understands that the Federal Law No. 319-FZ dated 14 July 14 2022 issued by the Federation of Russia is being implemented and as a consequence allows, amongst other dispositions, the holders of Russian domestic securities to directly request that the National Settlement Depository (NSD) transfers securities onto an owner account opened in the name of the beneficiary.

Clearstream Banking1 informs customers of the impact on the usual course of business with the securities deposited under Depository code 5R.

If a forced transfer is submitted by a holder of Russian domestic securities to the NSD, the Federal Law No. 319-FZ and the Procedure for interaction published by NSD, do not foresee any Ex-ante interaction with the FNH account holders (such as Clearstream Banking) but only post-ante reporting. According to information made available to Clearstream Banking, it is highly likely that the reporting will lack material information thus preventing a clean reconciliation in the books of Clearstream Banking. 
Clearstream Banking continues to not be able to fulfil neither its settlement nor its reconciliation obligations under the EU Central Securities Depository Regulation and the EU Finality Directive as it would be the case in normal circumstances. 

Impact on customers

With immediate effect and without any delay customers are requested to inform Clearstream Banking, if any of their proprietary holdings or the ones of their underlying clients in securities deposited under Depository code 5R, have been transferred under the forced transfer procedure detailed above. 

In light of the above, Clearstream Banking will continue to prevent internal, Bridge and domestic settlement of the securities deposited under Depository code 5R.

Further information

For further information, customers may contact Clearstream Banking Client Services or their Relationship Officer.

1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany, and registered in Register B of the Amtsgericht Frankfurt am Main, Germany, under number HRB 7500.