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About the author

Ana Giraldo

Chief Risk Officer and Director Americas | Management

Ana Giraldo is Thomas Murray’s Chief Risk Officer. She is based in Bogotá, Colombia, and also serves as Director, Americas. She leads our Risk Committee, and developed several internal risk methodologies to help clients assess their risk exposures to third parties. Ana is also the author of several technical papers on post-trade entities and risk.

Russian forces invaded Ukraine on Thursday, 24 February 2022. Global stock prices tumbled that day, while oil prices surged – increasing inflationary pressures. Since then, volatility has remained high in most financial markets.

The chronological impact on Ukrainian and Russian capital markets and financial market infrastructures


Initially, Ukraine was the most impacted market after the country’s president, Volodymyr Zelenskyy, declared martial law.

  • 24 February – Ukraine’s National Securities and Stock Market Commission (NSSMC) suspended the placement, circulation, and redemption of all securities from 11.00am (Kyiv time). Trading and clearing activities were suspended and the National Depository of Ukraine (NDU) was instructed to ensure the back-up of all information related to the accounts and securities held as of 11.00am.
  • 24 February – The National Bank of Ukraine (NBU) had to suspend the foreign exchange market and fixed the official exchange rate for 24 February 2022. Cross-border operations with foreign currencies were also suspended.

The market has remained closed for secondary market transactions since. It is uncertain when the market will be able to reopen. Asset safety has been compromised because investors are not able to access their assets. This could have significant implications for the capital markets. 

Investors with stocks in Ukraine are not able to sell them or receive income or dividend payments. In addition, since settlements are not taking place, any trades undertaken on Tuesday and Wednesday last week (22 and 23 February 2022) remain unsettled. Since no clearing and settlement activities are taking place, revenues at NDU are likely to diminish, with some implications for its financial risk. In addition, local companies are not able to get any financing through the primary and secondary market.


Russia has been severely affected as the war has continued to evolve, and economic sanctions have been imposed on its economy.

  • 24 February – The Moscow Exchange remained open on Thursday, although it had to activate its discrete auction mechanism to control volatility. The morning and evening trading sessions were cancelled, and the Central Bank (CBR) announced a series of measures to maintain the stability of the financial market and its liquidity.
  • 25 FebruaryStock prices bounced back after investors decided the sanctions against Russia were not as severe as they had expected.
  • 28 February – Clearstream Banking’s suspended Bridge settlement for all Russian domestic securities in all currencies. This will have a severe impact on the financial system. CBR suspended equity trading at the Moscow Exchange for three consecutive days, due to heightened volatility from additional and tougher sanctions on Russia. The development came after CBR raised its key policy rate from 9.5% to 20% in an emergency move to contain the risk of further depreciation of the Russian rouble (RUB). The RUB fell as much as 40% in offshore markets after Western nations announced additional sanctions against Russia. Key Russian banks were removed from the SWIFT interbank messaging system, and the assets of Russia’s CBR were frozen, limiting the country’s ability to access its overseas reserves. US President Biden’s administration banned US individuals and companies from doing business with the CBR, the Russian National Wealth Fund, and the Ministry of Finance.

In response to the sanctions, CBR ordered local custodians and registrars to stop the execution of settlement instructions on securities held by non-resident investors, as well as processing income payments linked to them.

Thomas Murray’s response

Thomas Murray has been closely monitoring the situation as sanctions and other actions are published.


We immediately reduced the country risk score for Ukraine, resulting in a downgrade in the Overall Risk Assessment for Ukraine from A- to BBB and further to B as additional measures were announced in our Market Asset Safety Risk Assessment (MASRA). 

The MASRA profiles provide a comprehensive overview of the factors affecting client assets in investment markets. This includes elements of country risk that could directly or indirectly trigger loss of principal, affect local market practices, and alter risks in the capital market infrastructure and sub-custody arrangements affecting the safekeeping, transfer, and servicing of underlying assets.

As of 1 March 2022, the outlook for the overall grade for our NDU risk assessment was revised to Negative as well as the outlooks for Asset Safety, Liquidity, and Financial Risks following the restrictions in the FX market and the market closure. A similar approach was taken for NBU Depository, with downgrades in the outlooks for Asset Safety, Liquidity, Financial, as well as the Overall risks. Operational Risk has been put On Watch.

The ratings for local sub-custodians have been maintained, although the Asset Safety, Asset Servicing and Financial risk outlooks as well as the Overall were changed to Negative. Further downgrades may take place as news from the conflict emerges.


The MASRA rating has been downgraded to B from A based on the latest measures implemented by CBR.

Following the instruction from CBR to local custodians and registrars (including NSD) to suspend the processing of settlement instructions and income payments for non-resident investors, the Asset Safety Risk and Asset Servicing risk assessments have been reduced to B for all local entities monitored by Thomas Murray (including Financial Market Infrastructures and local custodians). 

These changes have had an impact on their Overall grades. Outlooks have also been placed on Negative. Finally, Sberbanks’ and Unicredit’s financial risk ratings were lowered to BB with Negative Outlook as the banks’ situations have deteriorated following massive deposit withdrawals. Operational Risk has been put On Watch following the removal of some key banks from the SWIFT network.

Our Capital Market Infrastructure Risk Ratings (CMIRAs) for Russia and Ukraine have been reviewed and downgraded to B on the basis that foreign investors are not able to access their assets.

What happens next?

We will continue to monitor the situation as new events emerge and inform clients accordingly via Thomas Murray’s newsflashes. We are committed to reflecting the risk situation in both Ukraine and Russia by making the necessary adjustments to the information and the ratings in our reports based on these developments. Additional updates will be issued as the situation evolves.


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