HONG KONG STOCK EXCHANGE GUIDANCE ON ECONOMIC AND TRADE SANCTIONS

An article from Hogan Lovells is concerned with guidance issued by the Stock Exchange in a letter of 22nd March which provides additional clarity on the types of activities by listing applicants in jurisdictions, or with persons or entities, which are subject to economic or trade sanctions that may be a concern to the Stock Exchange as it evaluates a listing applicant’s suitability for listing.  The article focuses on changes and clarifications to that decision found in the letter.  The letter deals with situations where the applicant has engaged in primary sanctioned activity or in “secondary” sanctioned activity (i.e. such as if subject to restrictions under US secondary sanctions like those imposed in respect of Russia); and the applicant is  itself a target of sanctions, located, incorporated, organized or resident in a country that is subject to sanctions, or is a “Sanctioned Trader”.

https://hoganlovells.com/~/media/hogan-lovells/global/knowledge/publications/files/2019/2019_03_26_hkex-sanctions_guidance_letter.pdf

The letter itself is available at –

https://www.hkex.com.hk/-/media/HKEX-Market/Listing/Rules-and-Guidance/Interpretation-and-Guidance-Contingency/Guidance-Letters/Guidance-Letters-for-New-Applicants/gl101_19.pdf?la=en

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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