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An Investor Approach to Sanctions

Scanning for sanctions – a necessary due diligence activity?  Paul Malone says ‘yes’.   And managing the consequences can be challenging.

Paul Malone was our speaker and facilitator for our 17th August virtual meeting.  He covered the period from early 2022 when sanctions were applied to two of his share holdings, Evraz and Polymetal.  Discussion points included:

Introducing a gateway for firms who approve financial promotions.

Question: why should unauthorised firms be allowed to promote and sell their products at all in the UK?

Answer: we don’t know.

But there are many non‑compliant promotions being approved and then communicated by unauthorised firms to retail consumers resulting in harm because of inappropriate marketing and targeting.

Currently, any authorised person can generally approve financial promotions for

The new Audit Committee Standards – should we future proof them? That is the question.

Why not make this standard the minimum requirements expected of audit committees?

Why not use the standard to anticipate the wider authority ARGA will have?

The proposed standard is minimalist.  It limits focus on just some aspects – tendering, oversight of auditors and audits, and reporting. 

There are other responsibilities such as reviewing the company’s internal financial controls, and monitoring and reviewing the effectiveness of the company’s internal audit function.  These are absolute musts to ensure we can have an effective audit.

It’s important that we continue to fight for justice for Northern Rock shareholders. Therefore we need a new NRSAG committee.

Mo Majid is the one remaining committee member, supported by former committee member Pradeep Chand in an advisory capacity.

So assistance and support from NRSAG members is a must.  Please email the UKSA Office,, if you are interested in joining the committee.

Mo puts it clearly: We regroup and rethink or we retreat. There is no right or wrong approach. NRSAG has kept on fighting but when arguments fall on deaf ears regardless of their validity, well, it’s tough.

UKSA publishes its position on Dematerialisation

Since CREST and shares dematerialisation was introduced in the 1990s, shareholders’ rights have been eroded through intermediation. Following recent stock markets reviews, UKSA believes the UK may reverse this trend through using technology better and improved government regulation.

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