Note: These FAQs are subject to change. IBKR is continuing to monitor developments related to the sanctions on MOEX, NCC, and NSD.
A. Sanctions on MOEX, NCC, and NSD
In June 2024, the U.S. and the U.K. sanctioned the Moscow Exchange (MOEX), the Russian clearinghouse (NCC), and the Russian Depository (NSD). These sanctions generally prohibit transactions involving these entities by U.S. and U.K. people and entities, which includes Interactive Brokers LLC and Interactive Brokers (U.K.) Ltd. and, by extension, their affiliates.
The EU had previously imposed its own sanctions on NSD. As a result, EU persons cannot trade, transfer or convert non-sanctioned Russian securities, unless they have received a license from their relevant EU authority. (EU persons include EU nationals and persons located or doing business in the EU.)
1. What is the effect of the new sanctions?
Under the sanctions, IBKR customers are not allowed to conduct transactions involving MOEX, NCC, and NSD, unless separately authorized.
2. Is there a wind-down period for transactions under the U.S. and U.K. sanctions?
There is a wind-down period until October 12, 2024, during which clients can divest (close out) to non-U.S. persons non-sanctioned Russian securities traded on MOEX or cleared through the NCC/NSD. Starting October 12, non-sanctioned Russian securities will be fully restricted and you will not be able to trade or transfer your positions.
Under the pre-existing EU sanctions, EU persons are prohibited from engaging in any transactions in these securities.
3. Can I transfer my Russian securities positions to a non-U.S. broker?
Transfers of non-sanctioned Russian securities to a non-U.S. broker by non-EU persons for divestment purposes will be evaluated on a case-by-case basis. Requests should include an attestation that the transfer is for the purpose of divesting the holding to a non-U.S. person. IBKR reserves the right to reject or cancel pending transfers.
You currently cannot trade or transfer positions in sanctioned Russian securities held with IBKR. All positions in sanctioned Russian securities remain frozen until the sanctions are lifted or you receive a special license from OFAC.
4. Can I convert my Russian ADR/GDRs to local shares?
IBKR can process conversions of depository receipts on non-sanctioned Russian securities so long as the ADR/GDR is eligible for conversion and these transactions settle before October 12, 2024. IBKR will attempt to facilitate these conversions on a best-efforts basis and cannot guarantee the completion of the transaction. Pending ADR/GDR conversions of non-sanctioned Russian securities will be subject to cancellation on October 12, 2024.
5. Do es IBKR participate in the Russian “voluntary conversion” or forced transfer process?
The Russian government has established its own procedures through which Russian residents can convert Depository Receipts or submit a forced transfer of Russian securities to the NSD. In compliance with relevant sanctions laws and regulations, including those issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC"), IBKR does not participate in either process and will not provide signed and stamped statements, safekeeping certificates, or depository/custodian information for Russian securities that can be used to facilitate either process.