Russian-related sanctions
Clearstream Banking1 informs customers that effective
21 September 2022
domestic debt of the Russian federation (“OFZ”) denominated in RUB and held under depository 5R in Clearstream Banking’s system, can now be settled internally on a free of payment basis.
Clearstream Banking expects to open the window for instructions with an intended settlement date up to and including 11 October 2022.
Clearstream Banking notes the provisions of Russian law that enables investors in certain circumstances to receive deliveries from the account of certain holders of Foreign Nominee Accounts, such as Clearstream Banking, without the instruction of the account holder and considers that the risks of such delivery before 11 October 2022 are minimal.
Customers instructing the delivery of OFZ securities from their accounts with Clearstream Banking are required to ensure that the position to be delivered is not subject in whole or in part to any application to receive the securities in Russia.
Clearstream Banking reminds customers of the requirement to comply and ensure compliance by any of the customer’s underlying clients, with any applicable sanctions, including those of the EU, United States and the United Kingdom.
When instructing internal receipt or delivery of OFZs, Clearstream Banking customers must provide a representation of sanctions compliance in the narrative field of their instruction (for example, field :70E::SPRO// of the MT54x instruction) or in a separate authenticated message (for example, MT599) referencing the Transaction Reference to allow reconciliation of the representation back to the instruction.
The required sanctions representation wording is as follows: “SPRO//GL45COMP”
Whenever providing the above wording, the customer is attesting that the transaction would not benefit from the Russian Federal Law N°319 on “forced transfer” (date 14 July 2022) or any other Russian Federation acts issued after 24 February 2022 and would comply with any applicable sanctions, including those of the EU, United States and the United Kingdom, that it would not result in a violation of U.S. sanctions and that it complies with the related general licenses, in particular the transaction represents a divestment or transfer of, or facilitation of divestment or transfer of, debt covered under GL45 or its most recent successor, under OFAC’s Russian Harmful Foreign Activities sanctions program.
Further information
For further information, customers may contact Clearstream Banking Client Services or their Relationship Officer.
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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.