In the context of the European measures taken against Russia and Belarus, management companies are particularly concerned by the provisions of Article 5f of the amended EU Regulation 833/2014 for Russia and Regulation 398/2022 of 9 March 2022 for Belarus. These measures indeed provide that it is prohibited to sell euro-denominated securities issued after 12 April 2022, or units of collective investment undertakings offering exposure to such securities, to any Russian and Belarusian national, to any natural person resident in Russia and in Belarus or to any legal person, entity or body established in Russia and in Belarus.
This provision shall not apply to nationals of a Member State of the EU or to natural persons holding a temporary or permanent residence permit in a Member State of the EU.
Therefore, from 12.04.2022, Candriam Luxembourg, Belgium and France have requested to any company acting as a Distributor or Intermediary or Nominee of Funds to apply to themselves and/or to send an appropriate notice to any sub-distributor or sub-intermediary allowing their company to confirm the followings:
- They have taken all necessary measures to ensure full compliance with these EU Regulations (833/2014 and 398/2022);
- They report any breach of any element contained in this letter.