On 24 March, the EU Sanctions blog reported that the EU had released updated sanctions guidance in the form of FAQ, including on how or whether to aggregate ownership of a company by listed persons for the purposes of the 50% threshold.
https://www.europeansanctions.com/2022/03/eu-guidance-on-aggregation-in-russia-sanctions/
https://ec.europa.eu/info/business-economy-euro/banking-and-finance/international-relations/restrictive-measures-sanctions/sanctions-adopted-following-russias-military-aggression-against-ukraine_en
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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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