The London Stock Exchange’s AIM Team has released a notice (AIM Notice 40) alerting AIM companies and nominated advisers to their continuing need to keep up to date with international sanctions and to have due regard to their obligations in relation to them, both generally and particularly in the context of a nominated adviser’s consideration of whether a company’s shares are appropriate for admission to trading on the AIM market.

The release of the Notice was prompted by the developments in the Ukraine which resulted in the recent European Union sanctions against Russia, and refers to the consolidated list of persons and entities subject to UK and EU financial sanctions which is maintained on the HM Treasury website at www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets.

The AIM Notice also draws attention to the full text of the two EU Council Regulations (numbers 833/2014 and 960/2014) which provide for further restrictive measures against Russia. The London Stock Exchange requires all AIM companies to inform their nominated adviser immediately, if either now, or at any time in the future, they fall within these Regulations (or any amendments to them).

For so long as the sanctions remain in force, the Exchange does not expect to admit securities to trading on AIM which are issued by companies within the scope of the Regulations or any subsequent amendments. The AIM application process has been modified accordingly and the AIM application form (to admit securities to trading on AIM) has been changed to includes a confirmation that the company making the application does not fall under Articles 5.1 or 5.2 of Council Regulation (EU) No 833/2014, as amended by Council Regulation (EU) No 960/2014.

The Notice also serves as a timely reminder of the impact of international sanctions generally and the need for companies to observe them.  If a company is in breach of any sanctions this is likely to affect its appropriateness as an existing or applicant AIM company.

The full text of the AIM Notice is available via the following link:


Edwin Coe’s Corporate group has significant experience in advising on AIM market regulation and legal issues arising from an application for admission to AIM and the market’s continuing obligations. If you would like any further information about these or related topics, please contact Nick Williams by emailing nick.williams@edwincoe.com.

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