Sanctions against Russia and Belarus – Notice to issuers and their agents
In the context of the comprehensive sanctions regimes issued by relevant authorities of the European Union, the United Kingdom and the United States against Russia and Belarus within the last weeks, Clearstream Banking1 reminds all issuers of securities eligible in Clearstream Banking (including, but not limited to, bonds, equities, structured products and investment funds) and their agents of the following main (in a non-exhaustive manner) sanctions regimes which impose restrictions on issuers and their counterparties:
- EU: Council Regulation (EU) No 833/2014 (as amended) and Council Regulation (EU) No 269/2014 (as amended).
- UK: Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022.
- U.S.: Directives 1 and 2 under Executive Order (E.O) 14024.
Clearstream Banking adheres to these restrictions as and when applicable to it and expects herein all issuers and their agents to adhere to these restrictions and ensure adherence thereto by their relevant counterparties.
Clearstream Banking moreover advises all issuers and their agents to ensure that they clearly communicate notice of relevant sanctions regimes (as applicable) to both existing and new investors. It is therein the responsibility of the investor to observe such restrictions as specified in the Clearstream Banking General Terms and Conditions and Customer Handbook.
The above shall not be understood or construed as an exhaustive list or description of the relevant sanctions regimes applicable to issuers and their agents. It does not amount to legal advice, and issuers and their agents are invited to consult their own legal counsel in this respect.
Further information
For further information, customers may contact Clearstream Banking Client Services or their Relationship Officer.
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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany, and registered in Register B of the Amtsgericht Frankfurt am Main, Germany, under number HRB 7500.