As advised by our International Sanctions Legal Advisers after performing the procedures they consider necessary, our transactions with customers and suppliers involving the Relevant Regions during the Track Record Period were not sanctionable activities under Guidance Letter HKEX-GL101-19 given that (i) none of our customers/suppliers located in the Relevant Regions were identified on the Specially Designated Nationals and Blocked Persons List maintained by OFAC or the relevant restricted parties lists maintained by the European Union, Australia and the United Nations; and (ii) the services provided to the customers did not have a nexus to the United States or the EU and do not constitute Primary or Secondary Sanctionable Activities.
Business · p. 303
Our International Sanctions Legal Advisers have not identified apparent violations of the International Sanctions by us after evaluating the sanctions risks of our historical business activities relating to the Relevant Regions during the Track Record Period.
Business · p. 304
The company's explanation, the adviser's view and the page in the filing: see MattersOur Directors confirm that we do not have present intention to undertake any business involving directly or indirectly the Comprehensively Sanctioned Countries.
Business · p. 304