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.
Alexey Mashchenkov
FirstName
QIWI PLC LastNameAlexey Mashchenkov
Comapany
January 26,NameQIWI
2023 PLC
January
Page 2 26, 2023 Page 2
FirstName LastName
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