SEC Comment Letter 0000000000-23-000895 to QIWI (CIK 0001561566)
QIWI (CIK 0001561566)
Date: Jan. 26, 2023 · CIK: 0001561566 · Accession: 0000000000-23-000895
AI Filing Summary & Sentiment
File numbers found in text: 001-35893
Letter
United States securities and exchange commission logo January 26, 2023 Alexey Mashchenkov Chief Financial Officer QIWI PLC Kennedy 12, Kennedy Business Centre P.C. 1087 Nicosia, Cyprus Re:QIWI PLC Form 20-F for Fiscal Year Ended December 31, 2021 Response Dated December 29, 2022 File No. 001-35893 Dear Alexey Mashchenkov: We have reviewed your December 29, 2022 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 15, 2022 letter. Response Dated December 29, 2022 Board of Directors, page 116 1.We note your response to comment 10 and we reissue it. In future filings, please include the information that was provided in response to this comment regarding the types of reports that the board regularly receives and analyzes from management. Also, please specifically describe the extent and nature of the role of the board in overseeing risks related to Russia’s invasion of Ukraine, if any.
FirstName LastNameAlexey Mashchenkov Comapany NameQIWI PLC January 26, 2023 Page 2 FirstName LastName Alexey Mashchenkov QIWI PLC January 26, 2023 Page 2 You may contact Robert Shapiro at (202) 551-3273 or Lyn Shenk at (202) 551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Nicholas Nalbantian at (202) 551-7470 or Cara Wirth at (202) 551-7127 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Pranav Trivedi
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United States securities and exchange commission logo
January 26, 2023
Alexey Mashchenkov
Chief Financial Officer
QIWI PLC
Kennedy 12, Kennedy Business Centre
P.C. 1087
Nicosia, Cyprus
Re:QIWI PLC
Form 20-F for Fiscal Year Ended December 31, 2021
Response Dated December 29, 2022
File No. 001-35893
Dear Alexey Mashchenkov:
We have reviewed your December 29, 2022 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 15, 2022 letter.
Response Dated December 29, 2022
Board of Directors, page 116
1.We note your response to comment 10 and we reissue it. In future filings, please include
the information that was provided in response to this comment regarding the types of
reports that the board regularly receives and analyzes from management. Also,
please specifically describe the extent and nature of the role of the board in overseeing
risks related to Russia’s invasion of Ukraine, if any.
FirstName LastNameAlexey Mashchenkov
Comapany NameQIWI PLC
January 26, 2023 Page 2
FirstName LastName
Alexey Mashchenkov
QIWI PLC
January 26, 2023
Page 2
You may contact Robert Shapiro at (202) 551-3273 or Lyn Shenk at (202) 551-3380 if
you have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at (202) 551-7470 or Cara Wirth at (202) 551-7127 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Pranav Trivedi