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I have some ADR shares of PJSC Lukoil (LKOD, US69343P1057) that I bought on the London Stock Exchange via Interactive Brokers. I noticed that now I can neither sell my shares nor buy more of them. What happened to those shares? It seems that the LKOD ticker has disappeared from the London Stock Exchange. Does this mean that I have somehow lost my entire investment in PJSC Lukoil?

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2 Answers 2

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You've probably heard that there were a series of sanctions and countersanctions involving Russia in 2022 because of the war against Ukraine.

One of the first things that the Russian government has done with the ADRs held by nationals of countries they consider "unfriendly" (I will assume that means you) is that the ADRs were forcibly converted unto the underlying shares. Here is the April 2022 legal document (in Russian): http://publication.pravo.gov.ru/Document/View/0001202204160023?index=0&rangeSize=1\0 They got around implementing the conversion in August 2022.

That means that there is now an account in your name, somewhere in Russia, holding your shares, and another account, accumulating any dividends, denominated in rubles (local currency). You are not allowed to sell these shares as of now, but may be allowed to sell them in the future. You are also not allowed to convert the rubles into hard currency. You definitely have some asset, although it's not clear how valuable it is.

I suggest that you contact Citigroup, which administered the Lukoil ADRs, who may be able to explain the status of your ADRs. Their holders may one day receive some kind of compensation, but I doubt that it will happen soon.

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    How does the answer change if I am resident and national of a country that is not on the Unfriendly Countries List?
    – Flux
    Oct 23, 2022 at 14:31
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    I believe this means that you still have the converted shares in Russia, but are allowed to sell them even now, and also may be able to exchange the rubles into hard currency (although you may not like the "artificial" exchange rate). I hope Citi would be able to shed more light on their ADRs. Oct 23, 2022 at 14:36
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    "That means that there is now an account in your name, somewhere in Russia, holding your shares ..." — Is that applicable even if the shares are held in "street name" by my stock broker (Interactive Brokers), instead of being held in "direct registration" under my own name?
    – Flux
    Oct 23, 2022 at 14:50
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    I don't know, and while looking for an answer, I came across this recent article banki.ru/news/daytheme/?id=10974124 (In Russian, but Google translate works) that seems to say that the "C" account is actually in the name of the bank that administered the ADRs. Oct 23, 2022 at 15:07
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In the current geopolitical environment, Russian assets are very likely to be hard to do anything with.

In the particular case of Lukoil, it looks like the ADRs were suspended from trading by the LSE on 3rd March and then cancelled by Russia on 7th June.

The second article says

Persons who held ADRs as of April 27, 2022, may convert them into ordinary shares of the company by December 30, 2022, Lukoil noted.

But those would be shares traded on the Russian stock exchange and you might have extreme difficulty doing much with them. You might also need to be careful that you don't violate sanctions imposed by any country you live in or have citizenship of.

I don't know what would happen if you don't convert the ADRs but I imagine it'd make it even harder to extract any value from the shares.

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    What would happen to my Lukoil ADR shares if I hold them past December 30, 2022?
    – Flux
    Oct 23, 2022 at 8:38
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    @Flux Contact Citigroup as per the answer above, rather than asking strangers on the Internet. :)
    – xxbbcc
    Oct 25, 2022 at 0:55

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