EU restrictive measures against Russia

  • On 31 July 2014, the Council of the European Union (EU) issued Council Regulation No 833/2014, whereby it shall be prohibited to directly or indirectly purchase, sell, provide brokering or assistance in the issuance of, or otherwise deal with transferable securities and money-market instruments with a maturity exceeding 90 days, issued after 1 August 2014 by certain named entities, entities established outside the EU which are owned more than 50% by a named entity, or any person acting on behalf of or at the direction of the foregoing. 

 

  • On 8 September 2014,the Council of the European Union (EU) issued Council Regulation No 960/2014, amending Regulation 833/2014, whereby it shall also be prohibited to directly or indirectly purchase, sell, provide investment services for or assistance in the issuance of, or otherwise deal with transferable securities and money-market instruments with a maturity exceeding 30 days, issued after 12 September 2014, by certain named entities, entities established outside the EU which are owned more than 50% by a named entity, or any person acting on behalf of or at the direction of the foregoing.

 

 

  • The United Kingdom Financial Conduct Authority (FCA) has stated that for so long as the sanctions remain in force it does not expect to admit to listing securities issued after 1 August 2014 by issuers within the scope of the Regulation. It has also stated that it expects, for so long as the sanctions remain in force, that depositaries for GDR issuers within the scope of the Regulation will not issue new depositary receipts. The FCA notice can be found at:  http://www.fca.org.uk/about/what/protecting/financial-crime/money-laundering/events-ukraine

 

  • Details of the depositaries with depositary receipt programs admitted to trading on the International Order Book trading service, including closed notice for those programs, can be found at:

            BNY Mellon - http://www.adrbnymellon.com
            J.P. Morgan - https://www.adr.com
            Deutsche Bank - https://www.adr.db.com
            Citi - https://www.citi.com/dr

  • For so long as the sanctions remain in force the Exchange does not expect to admit to trading securities issued after 1 August 2014 by issuers within the scope of the Regulation.  Please also note that the Exchange has modified its admission to trading process (at draft and final Form 1 stages).  Issuers and/or advisers acting on the issuer’s behalf must now confirm to the Exchange that the issuer does not fall within the scope of the Regulation. 

            Member Firms are reminded that they must conduct their own due diligence to ensure they comply with any applicable current or future sanctions.

 

More detail on the sanctions and other UK and EU financial sanctions maintained by the United Kingdom HM Treasury can be found at:
https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets