By Maya Lester KC & Michael O’Kane

EU guidance on aggregation in Russia sanctions

The EU has published updated Guidance (FAQs) on asset freezes under its Russia sanctions regime. It is on the EU Guidance section of this site. Amongst other things, the Guidance covers aggregation. It says: If the aggregated ownership of a company by listed persons meets the 50% threshold, the company should be considered jointly owned and controlled by listed persons. …

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About Maya Lester KC

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Maya Lester KC is a senior barrister (King’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human...

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