DECISION

Kyiv

On approving the Procedure for forming the list of assets, including cash, belonging to clients/depositers of a professional participant of capital markets, to which a sanction in the form of "asset blocking" has been applied

In accordance with paragraph 1 of part 1 of Article 7, Article 29 of the Law of Ukraine "On State Regulation of Capital Markets and Organized Commodity Markets", part 8 of Article 5 of the Law of Ukraine "On Sanctions", and in order to ensure the National Commission on Securities and Stock Market implements the sanction in the form of "asset blocking" applied to a professional participant of capital markets by a decision of the National Security and Defense Council of Ukraine, brought into force by a Decree of the President of Ukraine,

The National Commission on Securities and Stock Market

HAS DECIDED:

1. Approve the Procedure for forming the list of assets, including cash, belonging to clients/depositers of a professional participant of capital markets, to which a sanction in the form of "asset blocking" has been applied, attached hereto.

2. The Department of Methodology for Regulation of Professional Participants of the Securities Market shall ensure submission of this decision for state registration to the Ministry of Justice of Ukraine.

3. The Administration of Administrative Activities shall ensure publication of this decision on the official website of the National Commission on Securities and Stock Market.

4. The Department of Legal Support and Internal Compliance Control, after state registration of the decision by the Ministry of Justice of Ukraine, shall ensure publication of this decision on the official website of the National Commission on Securities and Stock Market.

5. This decision enters into force on the day following the day of its official publication.

6. Control over the implementation of this decision shall be entrusted to members of the National Commission on Securities and Stock Market Ya. Shliakhov and I. Baramiya.

Chairman of the Commission Ruslan MAGOMEDOV

Protocol of the Commission meeting of 13.05.2025 No. 56

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APPROVED Decision of the National Commission on Securities and Stock Market ______________No.

Procedure for forming the list of assets, including cash, belonging to clients/depositers of a professional participant of capital markets, to which a sanction in the form of "asset blocking" has been applied

1. This Procedure applies in the event of a decision by the National Security and Defense Council of Ukraine, brought into force by a Decree of the President of Ukraine in accordance with the Law of Ukraine "On Sanctions", which provides for the formation by the National Commission on Securities and Stock Market (hereinafter - NSSM) of a list of assets, including cash, belonging to clients/depositers of a professional participant of capital markets, which has licenses for professional activities in capital markets, namely activities for trading financial instruments and depository activities for their separate types, to which such a decision of the National Security and Defense Council of Ukraine applies a sanction in the form of "asset blocking", provided for in paragraph 1 of part 1 of Article 4 of the Law of Ukraine "On Sanctions" (hereinafter - sanctioned professional participant).

The Procedure defines the process of NSSM forming the List of assets, including cash, belonging to clients/depositers of the sanctioned professional participant (hereinafter - the List).

2. In this Procedure, the term "client/depositor" is used in the following meaning: client/depositor – a person to whom services were provided by the sanctioned professional participant on the basis of a contract(s) defined by law within the scope of professional activities in capital markets, namely activities for trading financial instruments and depository activities for their separate types, indicated in relation to them in the register of professional participants of capital markets and organized commodity markets, or the owner of securities transferred to electronic form, the securities account of which was opened and serviced by the sanctioned professional participant, on the basis of a contract concluded with the issuer of such securities on opening/servicing securities accounts for owners.

3. As a result of reconciling data on depository accounting of securities regarding securities and data on cash belonging to clients/depositers of the sanctioned professional participant or the right to which clients/depositers of the sanctioned professional participant have, based on information and documents obtained in response to requests/demands of the NSSM from the sanctioned professional participant, the Central Depository of Securities (hereinafter - Central Depository), the National Bank of Ukraine, and JSC "Clearing Center for Servicing Agreements on Financial Markets" (hereinafter - Clearing Center), the NSSM forms the List, which consists of sections by types of clients/depositers of the sanctioned professional participant (natural person, legal entity, unit investment fund), each of which is divided into parts by such entities:

Part 1. Central Depository, which carries out depository accounting of securities on securities accounts of the sanctioned professional participant, and on whose accounts funds that were not transferred to the account of the sanctioned professional participant for further payment to clients/depositers are located;

Part 2. National Bank of Ukraine, which carries out depository accounting of securities on securities accounts of the sanctioned professional participant, as well as accounting of cash not paid to clients/depositers of the sanctioned professional participant;

Part 3. Clearing Center, in the system of clearing accounting of which information regarding cash belonging to clients/depositers of the sanctioned professional participant is accounted;

Part 4. Banks, in which on the accounts of the sanctioned professional participant, unpaid cash of clients/depositers of the sanctioned professional participant is accounted.

The List is compiled in the form provided in the appendix to this Procedure, in Excel (.xlsx) format. Clients/depositers of the sanctioned professional participant are placed in each part of the List in alphabetical order.

Regarding each client/depositor of the sanctioned professional participant included in the List, the following must be indicated:

1. for a natural person: a) identification data:

   • surname, first name, patronymic (if available);
   • number (and if available - series) of the passport of a citizen of Ukraine (or another document certifying identity and which, in accordance with Ukrainian legislation, can be used on the territory of Ukraine to conclude transactions – for natural persons who are non-residents);
   • registration number of the taxpayer's account card or number (and if available - series) of the passport of a citizen of Ukraine, in which a mark is placed on refusal to accept the registration number of the taxpayer's account card, or passport number with a record on refusal to accept the registration number of the taxpayer's account card in an electronic contactless carrier – for natural persons who are residents; b) information on securities belonging to the natural person:
   • name of the issuer;
   • identification code of the legal entity in the Unified State Register of Enterprises and Organizations of Ukraine (hereinafter - EDROU code) – for issuers who are residents;
   • identification code from the commercial, court, or bank register of the country where the issuer of securities is officially registered – for issuers who are non-residents;
   • Legal Entity Identifier (LEI code) (if available);
   • code in the Unified State Register of Joint Investment Institutions (hereinafter - EDRIJI code) – for joint investment institutions;
   • International Securities Identification Number (ISIN);
   • type of issue securities;
   • quantity of securities of each issue;
   • nominal value of one security; c) information on the amount of cash belonging to the natural person, and the name of the currency;

2. for a legal entity: a) identification data:

   • full or abbreviated (if available) name;
   • EDROU code – for legal entities who are residents;
   • identification code from the commercial, bank, or court register or information on the registration of the legal entity in accordance with the legislation of the country of its location – for legal entities who are non-residents;
   • LEI code (if available);
   • full name and EDROU code – for the asset management company acting in the interests of a corporate investment fund (in case of an asset management agreement); EDRIJI code – for corporate investment funds; b) information on securities belonging to the legal entity:
   • name of the issuer;
   • EDROU code – for issuer-residents;
   • identification code from the commercial, court, or bank register of the country where the issuer of securities is officially registered – for issuers who are non-residents;
   • LEI code (if available);
   • EDRIJI code – for joint investment institutions;
   • International Securities Identification Number (ISIN);
   • type of issue securities;
   • quantity of securities of each issue;
   • nominal value of one security; c) information on the amount of cash belonging to the legal entity, and the name of the currency;

3. for a unit investment fund: a) identification data:

   • full or abbreviated (if available) name of the asset management company that created the unit investment fund;
   • full or abbreviated (if available) name of the unit investment fund;
   • EDROU code of the asset management company that created the unit investment fund;
   • EDRIJI code of the unit investment fund; b) information on securities belonging to the unit investment fund:
   • name of the issuer;
   • EDROU code – for issuer-residents;
   • identification code from the commercial, court, or bank register of the country where the issuer of securities is officially registered – for issuers who are non-residents;
   • LEI code (if available);
   • EDRIJI code – for joint investment institutions;
   • International Securities Identification Number (ISIN);
   • type of issue securities;
   • quantity of securities of each issue;
   • nominal value of one security; c) information on the amount of cash belonging to the unit investment fund, and the name of the currency;

4. The draft List is approved by the NSSM as a collegial body.

Parts of the Draft List are sent by the NSSM to the sanctioned professional participant, the Central Depository, the National Bank of Ukraine, and banks in which unpaid cash of clients/depositers of the sanctioned professional participant is accounted, for verification of the amounts of cash belonging to clients/depositers of the sanctioned professional participant. The relevant entities notify the NSSM of the results of reviewing the request/demand of the NSSM within a period of no more than 5 working days.

5. The NSSM approves the approved draft List as a collegial body after verifying data regarding clients/depositers of the sanctioned professional participant for the presence of information indicating the impossibility of including the client/depositor of the sanctioned professional participant and their assets in the approved List. Such information includes any of the following criteria:

1. the person is or was within five years prior to the application of sanctions to the sanctioned professional participant a controller, ultimate beneficial owner, related person of the sanctioned professional participant, exercised or exercises control (decisive influence) over it;

2. the person is a natural person who has citizenship of a state that carries out armed aggression against Ukraine in the meaning provided in Article 1 of the Law of Ukraine "On Defense of Ukraine" (hereinafter - aggressor state), or whose place of permanent residence (stay, registration) is the aggressor state, except for natural persons who reside on the territory of Ukraine on legal grounds and/or who have been granted the status of combatants after April 14, 2014;

3. the person is a legal entity created and registered in accordance with the legislation of the aggressor state;

4. the person is a legal entity created and registered in accordance with the legislation of Ukraine, the controller, ultimate beneficial owner of which is the aggressor state, and/or the person specified in subparagraphs 1 - 3 of this paragraph;

5. the person is a person to whom special economic and other restrictive measures (sanctions) have been applied in accordance with the Law of Ukraine "On Sanctions";

6. the person is a person included in the list of persons related to terrorist activities, or regarding whom international sanctions have been applied;

7. the person is a head of a legal entity that is or was within five years prior to the application of sanctions to the sanctioned professional participant closely related to the sanctioned professional participant.

For verification of data regarding the compliance of the client/depositor of the sanctioned professional participant with the criteria defined in this paragraph, the NSSM sends an information request regarding such client/depositor of the sanctioned professional participant to the Security Service of Ukraine. For obtaining additional information, the NSSM may send an information request regarding such client/depositor of the sanctioned professional participant to other bodies defined in the corresponding decision of the National Security and Defense Council of Ukraine on the application of sanctions, as bodies that ensure the implementation and monitoring of the effectiveness of personal special economic and other restrictive measures (sanctions).

6. A client/depositor of the sanctioned professional participant, regarding whom there is information about their compliance with at least one of the criteria defined in paragraph 5 of this Procedure, is not included in the List.

7. The approved List, together with the NSSM act on its approval, is provided for conducting further measures to return assets, including cash, to clients/depositers of the sanctioned professional participant:

• to the sanctioned professional participant – in full volume;
• to the Central Depository – Parts 1 of Section I, Section II, Section III of the List;
• to the National Bank of Ukraine – Parts 2 of Section I, Section II, Section III of the List;
• to the Clearing Center – Parts 3 of Section I, Section II, Section III of the List;
• to the respective banks – Parts 4 of Section I, Section II, Section III of the List.

The procedure for actions of capital market participants on returning assets, including cash, to clients/depositers of the sanctioned professional participant is established by the NSSM in coordination with the National Bank of Ukraine in the part of actions of the National Bank of Ukraine and subjects, state regulation and supervision of whose activities is carried out by the National Bank of Ukraine.

Director of the Department of Methodology for Regulation of Professional Participants of the Securities Market Maxim TYMOKHIN

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Appendix to the Procedure for forming the list of assets, including cash, belonging to clients/depositers of a professional participant of capital markets, to which a sanction in the form of "asset blocking" has been applied (paragraph 3)

List of assets, including cash, belonging to clients/depositers of

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(name of the sanctioned professional participant of capital markets, to which the "asset blocking" sanction has been applied (hereinafter - SPP))

Section I. Natural Persons

Securities	Cash
Full Name¹	Amount
Passport Series (if available)	Currency Name
Passport Number
Identification Code
Name of Issuer
EDROU Code of Issuer²
LEI Code (if available)
EDRIJI Code of Issuer³
ISIN Code
Type of Issue Security
Quantity of Securities
Nominal Value of One Security
1	2

Part 1. Central Depository of Securities Part 2. National Bank of Ukraine Part 3. JSC "Clearing Center for Servicing Agreements on Financial Markets" Part 4. Bank⁷

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Continuation of Appendix

Section II. Legal Entities

Securities	Cash
Name	EDROU Code¹
LEI Code (if available)	EDRIJI Code³
Name of AM⁴	EDROU Code of AM⁴
Name of Issuer	EDROU Code of Issuer²
LEI Code of Issuer (if available)	EDRIJI Code of Issuer³
ISIN Code
Type of Security
Quantity of Securities
Nominal Value of One Security
1	2

Part 1. Central Depository of Securities Part 2. National Bank of Ukraine Part 3. JSC "Clearing Center for Servicing Agreements on Financial Markets" Part 4. Bank⁷

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Continuation of Appendix

Section III. Unit Investment Funds

Securities	Cash
Full Name of UIF⁵	EDRIJI Code of UIF
Name of AM⁶	EDROU Code of AM⁶
Name of Issuer	Identification Code of Issuer³
LEI Code of Issuer (if available)	EDRIJI Code of Issuer³
ISIN Code
Type of Issue Security
Quantity of Securities
Nominal Value of One Security
1	2

Part 1. Central Depository of Securities Part 2. National Bank of Ukraine Part 3. JSC "Clearing Center for Servicing Agreements on Financial Markets" Part 4. Bank⁷

Notes:

1 - Surname, first name, patronymic (if available); 2 - Identification code of the legal entity in the Unified State Register of Enterprises and Organizations of Ukraine – for issuer-residents, clients/depositers of SPP; identification code from the commercial, bank, or court register or information on the registration of the legal entity in accordance with the legislation of the country of its location – for issuer-non-residents; 3 - for issuers of securities of joint investment institutions; 4 - full name and identification code of the legal entity in the Unified State Register of Enterprises and Organizations of Ukraine of the asset management company acting in the interests of this corporate investment fund (in case of an asset management agreement) – for corporate investment funds; 5 - full or abbreviated (if available) name of the UIF; 6 - asset management company that created the UIF; 7 - name of the bank.