Private Placement Numerical Quota Restriction
The private placement laws and regulations of certain countries permit the marketing and/or promotion of a financial product to a limited number of investors during a specified period of time. By way of example: the laws and regulations of a country may permit the marketing and/or promotion of a financial product to 99 investors per annum in that country. Such provisions may be termed “Quota Exemptions”.
With multiple Distribution Partners operating in the same country, there are risks associated with the use of Quota Exemptions. Collectively, and in aggregate, Distribution Partners may inadvertently breach the Quota Exemption limits. This is because each Distribution Partner would not be aware of the extent to which the quota has already been used up by another Distribution Partner.
The risks of breaching Quota Exemption limits are relevant not only to the Funds, but also to Distribution Partners. As such, the Global Distributor of Aberdeen’s Luxembourg Fund Range has decided to impose a complete restriction on the use of any Quota Exemption in respect of the marketing and/or promotion of the Funds.
As such, Distribution Partners may not utilise a Quota Exemption to market and/or promote any share class or sub-fund of any Fund. For the avoidance of doubt, this restriction applies globally.
Aberdeen Restricted Countries List
Aberdeen maintains a “Restricted Countries List”, set out below. This list includes:
- countries where it is not possible to sell financial products due to international sanctions or similar restrictions; and
- countries where Aberdeen has decided that the risks are sufficiently great to warrant the total restriction of marketing/promotion of its products.
The Transfer Agent of the Funds does not accept investments from any investor, whether retail or corporate, residing, domiciled or incorporated in a country included within the Restricted Countries List.
Distribution Partners may not market, promote or sell any share-class or sub-fund of any Fund to any current or potential investor, whether retail or corporate, residing, domiciled or incorporated in a country included within the Restricted Countries List.
Bosnia and Herzegovina
Central African Republic
Congo (Democratic Republic of)
Guinea (Democratic Republic of)
North Korea (Democratic People’s Republic of)
Palestine (Gaza Strip and West Bank)
Sudan and South Sudan
Valid on and from December 2019