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New UK License Authorizes Certain Transfers Involving Sanctioned Brokers

The U.K. issued a new Russian sanctions general license allowing non-designated parties who have made investments through sanctioned brokers to "transfer their funds to a non-designated broker." The license applies when the only sanctioned party involved is the broker. Under…

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the license, an "Asset Holding Institution" can take steps to transfer any funds held by a central securities depository that the asset-holding institution "reasonably considers" are "investment assets of that" non-sanctioned account holder and relate to investment made by the non-sanctioned account holder with the sanctioned broker before it became sanctioned.