Have you registered for your LEI?

Why do you need to register?

On 13 October, the London Stock Exchange published AIM Notice 47 on the requirement for AIM companies to have a LEI.
The purpose behind registering for an LEI is so that a global reference data system that uniquely identifies every legal entity or structure, in any jurisdiction, that is party to a financial transaction can be created.
Further, it will ensure compliance with the obligations under Markets in Financial Instrument Directive and Market Abuse Regulation, which require market operators (London Stock Exchange, in this instance), to collate LEI codes for each issuer with securities admitted to trading (which includes all AIM companies).

What does this mean for you if you are an AIM listed company?

You can check whether an LEI already exists using the search function on the Global Legal Entity Identifier Foundation website here.

If you have no LEI, by 30 November 2017, you must have registered for one from a Local Operating Unit (“LOU”). London Stock Exchange is such an LOU and has produced the LEI Quick Step User Guide for its web-based platform (please see Useful Links below).

London Stock Exchange will be charging an initial allocation cost of £115+VAT and annual maintenance cost of £70+VAT per LEI. For requests of ten or more LEIs, the London Stock Exchange can provide a bulk service.
The AIM Notice also notes that it is an AIM company’s responsibility to ensure that it’s LEI is renewed according to the terms of any of the accredited LOUs of the Global LEI Foundation (i.e. London Stock Exchange).

Useful Links:

London Stock Exchange Guidance: https://www.lseg.com/LEI
London Stock Exchange Quick User guide: www2.londonstockexchangegroup.com/requesting-LEI-quick-guide
London Stock Exchange Full LEI User Guide: www2.londonstockexchangegroup.com/LEI-User-Guide
Register for your LEI here: www2.londonstockexchangegroup.com/register-for-lei.

Memery Crystal is a specialist international law firm based in London with a well-established history of acting for clients in the corporate sector and can offer advice on any issues, including those raised in the article: registering for an LEI and obligations under Markets in Financial Instrument Directive and Market Abuse Regulation. As an industry-leading advisor in AIM, Memery Crystal have again been included in “Band 1” in the most recent edition of the Chambers UK legal directory.