Information memo: Belarus, Russia

Dear partner,

We would like to draw your attention to Article 5f of Regulation (EU) 833/2014 and Article 1y of Regulation (EU) 2022/398, references for which can be found in the appendix.

These texts prohibit the sale of the following to any Russian or Belarusian national or natural person residing in Russia or Belarus or any legal person, entity or body established in Russia or Belarus:

• Euro-denominated transferable securities issued after 12 April 2022;
  
• Units in collective investment undertakings providing exposure to such securities.
  

This prohibition does not apply to nationals of a Member State or natural persons having a temporary or permanent residence permit in a Member State.

This measure applies to units and shares of funds managed by the Carmignac Group.

Selling units or shares of funds managed by the Carmignac Group to persons meeting the criteria set out above is therefore prohibited, including as regards subsequent subscriptions of fund units or shares by investors already in possession of or exposed to such funds.

Should an existing investor meet the prohibition criteria, we kindly ask that you let us know.

Yours faithfully.

Appendix :

Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine
Article 5f
1. It shall be prohibited to sell euro denominated transferable securities issued after 12 April 2022 or units in collective investment undertakings providing exposure to such securities, to any Russian national or natural person residing in Russia or any legal person, entity or body established in Russia.
2. Paragraph 1 shall not apply to nationals of a Member State or natural persons having a temporary or permanent residence permit in a Member State.

Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine
Article 1y
1. It shall be prohibited to sell euro denominated transferable securities issued after 12 April 2022 or units in collective investment undertakings providing exposure to such securities, to any Belarusian national or natural person residing in Belarus or any legal person, entity or body established in Belarus.
2. Paragraph 1 shall not apply to nationals of a Member State or natural persons having a temporary or permanent residence permit in a Member State.