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J.P. Morgan notifies Russian investor of Sberbank shares sold at 70% discount

J.P. Morgan informed a Russian retail investor that Sberbank shares were sold at a 70% discount to the Moscow Exchange closing price from March 13, 2026, without prior disclosure from Russian regulators. The discount exceeded the standard mandatory 60% for foreign exits, and no budget contribution was paid. The buyer, a non-sanctioned entity, was not identified.


Quick Facts
Who
J.P. Morgan
What
Sale of Sberbank ordinary shares underlying ADRs at 70% discount
When
June 8, 2026 (date of letter)
Where
Newark, Delaware, USA (J.P. Morgan office)
- Sale of Sberbank ordinary shares underlying ADRs at 70% discount
- Notification sent by J.P. Morgan to a Russian investor
- Transaction executed without prior official Russian disclosure
- No exit tax or budget contribution paid
- Buyer described as non-sanctioned but not named
A Russian retail investor has received a notification from J.P. Morgan, acting as depositary for Sberbank American Depositary Receipts (ADRs), that a portion of the bank’s underlying shares was sold at a 70% discount to their market price on the Moscow Exchange on March 13, 2026. The transaction was executed without prior disclosure by Russian authorities, including the Central Bank or the Government Commission on the Control of Foreign Investments.
The correspondence, dated June 8, 2026, and sent from J.P. Morgan’s office in Newark, Delaware, stated that the sale price per ordinary share was set at 30% of the closing price on March 13, 2026 – approximately 312 rubles per share at that time. Converted at the official exchange rate of 79.07 rubles per dollar, the price amounted to about $1.184 per share, or less than 100 rubles – roughly one-third of the price domestic Russian investors could pay on the exchange. The buyer, described only as a "non-sanctioned" entity, was not named in the document.
The discount appears to exceed the standard mandatory 60% discount set by Russian regulations for foreign investors exiting Russian assets. Under Presidential Decree No. 520, effective since August 2022, sales of shares owned by "unfriendly" non-residents require special permission from a sub-commission of the Government Commission chaired by Finance Minister Anton Siluanov. Since October 2024, that sub-commission has required a minimum 60% discount on market price plus a voluntary contribution of 35% to the federal budget. In this case, however, the discount was 70% – deeper than the standard – and no exit tax or contribution to the budget was paid, according to the notification.
The transaction may have been executed under an individual government resolution and a specific license from the U.S. Office of Foreign Assets Control (OFAC) permitting the sale of sanctioned Sberbank securities to a non-sanctioned buyer. Observers note a possible link to Presidential Order No. 81-rp of March 17, 2025, which authorized U.S. hedge fund 683 Capital Partners to purchase securities of Russian companies from Western funds and resell them to Russian structures, such as Cepheus-2 and former Sber Real Estate Funds. Deputy Finance Minister Alexei Moiseev described that authorization as a "one-off case."
The source of the discounted shares is the ADR program that was terminated on June 16, 2022. The underlying shares that had not been exchanged by Russian investors during the brief conversion window remained in a suspended state until this June 2026 sale. Neither Sberbank, the Central Bank, nor the Government Commission have commented publicly on the transaction.
Why This Matters
This transaction signals that Western financial institutions, even under sanctions, continue to execute asset sales involving Russian securities at discounts that exceed legal requirements, without disclosure to Russian regulators. For investors and compliance professionals, it underscores the risks of holding sanctioned assets, the lack of transparency in ADR conversions, and potential hidden channels for capital flight or asset recovery outside official frameworks.
Timeline & Sources
Jun 16, 2022
WireSberbank ADR program terminated.
Aug 1, 2022
WirePresidential Decree No. 520 enacted requiring special permission for non-resident asset sales.
Oct 1, 2024
WireMinimum discount for non-resident exits increased to 60% and mandatory budget contribution to 35%.
Mar 17, 2025
WirePresidential Order No. 81-rp authorizes 683 Capital Partners to buy Russian securities from Western funds.
Mar 13, 2026
WireReference date for share price: Sber ordinary share closes at ~312 rubles on Moscow Exchange.
Jun 8, 2026
WireJ.P. Morgan sends notification to investor about sale of Sber shares at 70% discount.
Jun 18, 2026
WireSmart-Lab blog publishes investor's account of the transaction.