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“.
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