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UKLA and AIM require sanctions confirmation

Brad Isaac


United Kingdom

Market reCap September 2014 edition 


The UK Listing Authority (UKLA) is asking companies to confirm that they are not subject to the European Union sanctions recently imposed in view of Russia's actions destabilising the situation in Ukraine when they submit a prospectus for approval.

The relevant EU Regulation came into force with effect from 1 August 2014.  It prohibits the purchase, sale or other dealings in transferable securities and money-market instruments with a maturity exceeding 90 days issued by certain Russian institutions and others connected with them, and the provision of brokering or assistance with the issuance of such securities and instruments.  The institutions are Sberbank, VTB Bank, Gazprombank, Vnesheconombank and Rosselkhozbank.

As a result, the UKLA is now requiring issuers to confirm that they are not a legal person, entity or body:

  • established outside the European Union whose proprietary rights are owned for more than 50% by one of these Russian institutions; or

  • acting on behalf or at the direction of one of these institutions or a legal person, entity or body within the above bullet point.

The UKLA also requires the issuer to confirm that it will inform the UKLA as soon as practicable if its circumstances change and the sanctions confirmation it has provided ceases to be valid. 

We are also aware that AIM is requiring nominated advisers to provide a similar sanctions confirmation on behalf of an AIM Company when it applies to have shares admitted to trading.


Brad Isaac is a Partner in Fieldfisher's Corporate Group in London.