Executive Summary
On Friday 22nd March 2019, the Stock Exchange of Hong Kong
(HKEx) released a guidance letter that provides
additional clarity on the types of activities by listing applicants
in jurisdictions, or with persons or entities, which are subject to
economic or trade sanctions that may be a concern to the HKEx as it
evaluates a listing applicant's suitability for listing
(Guidance Letter). The Guidance Letter is in many
ways consistent with HKEx Listing Decision LD76-2013, which was
published by the HKEx in December 2013
(LD76-2013). However, the Guidance Letter goes
beyond the LD76-2013 in several important ways:
- The Guidance Letter provides
additional clarity as to what conduct is of concern to the HKEx
through the use of a number of defined terms that have precise
language.