RUSSIA SANCTIONS: MINORITY SHARES OF SANCTIONED PERSONS IN NON-LISTED COMPANIES TO BE AGGREGATED IN FUTURE

An article from Oppenhof & Partner in Germany on 22 June considers new FAQ from the EU on interpretation of the sanctions on Russia.  It starts by saying that, generally, a listed person holds an ownership position in a third party in case of a majority shareholding, i.e. if the listed person holds more than 50% of the shares in the company (so-called “50% rule”).  However, the updated FAQ says that “One should take into account the aggregated ownership of the entity.  For example, if one listed person owns 30% of the entity and another listed person owns 25% of the entity, the entity should be considered as owned by listed persons“. 

https://www.mondaq.com/germany/export-controls-trade-investment-sanctions/1204416/russia-sanctions-minority-shares-of-sanctioned-persons-in-non-listed-companies-to-be-aggregated-in-future-further-non-sanctioned-companies-possibly-also-affected

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

https://www.buymeacoffee.com/KoIvM842y

NOTE THAT THE ABOVE LINK IS NOW CORRECTED AND WORKS!

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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