Short summary: I'm not quite sure if I've understood this correctly, but with this offer you are exchanging ADRs for ordinary shares, which Clearstream says you can't hold in your non-Russian securities account. I have now done a bit of DR. Google and he told me that you have to open a custody account at the non-sanctioned Gazprombank, so the ordinary shares will be deposited there for you. So in the first step you have to open a type C account (https://www.clearstream.com/clearstream-en/products-and-services/settlement/a22055-3052412) & a custody account at Gazprombank, whether this will be successful I actually don't know. In the future, your dividends will be booked on this account, but in rubles, since it is a ruble account. However, I have not yet read of any case where this worked or was already processed. Source: Gazprombank https://www.gazprombank.ru/docs/drcancellationeng/