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Taiwan lifts forex trading punishment on Deutsche -sources

A Deutsche Bank logo adorns a wall at the company’s headquarters in Frankfurt, Germany June 9, 2015. REUTERS/Ralph Orlowski

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TAIPEI, Feb 7 (Reuters) – Taiwan’s central bank has allowed Deutsche Bank (DBKGn.DE) to start trading Taiwan dollar deliverable and non-deliverable forwards again, three sources told Reuters, after it suspended them as part of a crackdown on speculation last February.

The central bank issued the two-year punishment to Deutsche following a case where it said foreign banks helped grain companies engage in currency speculation through deliverable forwards, affecting the stability of Taiwan’s foreign exchange market. read more

The Taiwan dollar has strengthened against the U.S. dollar as the island’s trade-dependent economy boomed on global demand for its tech products fuelled by people working from home during the COVID-19 pandemic.

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Three sources briefed on the matter told Reuters the central bank had quietly allowed Deutsche Bank to resume the forwards trading. They spoke on condition of anonymity as they were not authorised to speak to the media.

Deutsche Bank declined to comment, while Taiwan’s central bank did not respond to a request for comment.

One of the sources said the move was based on the bank cooperating on “improvement measures”, and because not only is it the only German bank in Taiwan, it has also operated on the island for many years.

A second source said the bank had responded to “motivation” to fix its processes.

Last July, the central bank lifted related foreign exchange trading curbs early on ING (INGA.AS) and Australia and New Zealand Banking Group Ltd (ANZ) (ANZ.AX) for their involvement in the same case. read more

The central bank has been concerned that the strong Taiwan dollar could make exports from the trade-dependent island more expensive and possibly put it in the crosshairs of the United States as a currency manipulator.

Taiwan, along with Vietnam, again exceeded the U.S. Treasury’s thresholds for possible currency manipulation and enhanced analysis under a 2015 trade law, but the department in December refrained from formally branding them as manipulators. read more

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Reporting by Liang-sa Loh; Additional reporting by Ben Blanchard; Editing by Kirsten Donovan

Our Standards: The Thomson Reuters Trust Principles.


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S. China border port ensures smooth int’l trade during Spring Festival–China Economic Net

Youyi Port in Pingxiang City, south China’s Guangxi Zhuang Autonomous Region, is still busy during the Spring Festival this year.

Lyu Jinfu, a freight forwarder, was busy handling documents and guiding trucks to move.

For epidemic prevention and control, Lyu has not been able to go home for eight months and has spent every day in closed-loop management. “On New Year’s Eve this year, I made a video call to my families,” said Lyu.

Cross-border driver Yu Zhijun also began a busy day early. He drove a truck loaded with mangoes, longan, and other Vietnamese fruits, passed through the intelligent customs clearance scheduling system from the checkpoint, and entered the designated warehouse through the port for goods transfer.

“There are so many goods these days that I have to make seven or eight trips a day,” Yu said. In Pingxiang, there are now more than 300 freight forwarders and cross-border drivers commuting between the port and warehouses every day, up to more than 600 at peak times.

Youyi Port is an important exit and entry channel for people, as well as a main land channel from China to ASEAN destinations, with frequent cross-border personnel and goods exchanges. Since the outbreak of COVID-19, over 700 personnel and 1,300 vehicles enter and leave the port on a peak day.

The local government has strictly implemented epidemic prevention and control measures to prevent imported cases, ensure the smooth flow of cross-border channels, and safeguard the security of China’s southern border.

In 2021, Youyi port’s foreign trade continued to grow. It saw a total of 402,800 inbound and outbound freight trucks and about 4.4 million tonnes of import and export cargo.

According to Yu Ruida, deputy director of Pingxiang Commerce and Port Administration, the local government has innovatively introduced a customs clearance agent driving system for cross-border drivers, and all Chinese freight vehicles entering and leaving the port are driven by designated cross-border drivers who are strictly under closed-loop management.

Besides, cross-border vehicles are comprehensively disinfected, and imported goods can enter China only after undergoing nucleic acid testing, disinfection and other procedures.

At the Beitou warehouse in Pingxiang, cars with Vietnamese or Chinese license plates shuttled back and forth, and staff in protective suits were busy loading and unloading goods.

According to Zhang Yaoquan, manager of the warehouse, all goods from overseas need to have nucleic acid testing first, and only if the result of the test is negative can they be loaded and unloaded.

Fruits from ASEAN countries enter the Chinese market through Youyi Port every day. “Our company carries many durian, dragon fruit, longan, and other ASEAN fruits,” said Su Yu, head of the operation Department of Guangxi Xiangxiang International Logistics Co., LTD.

According to Su, now both the port and the company have attached great importance to the safety of cross-border cold chain logistics, and have made every effort to prevent products with the virus from entering China.

“Despite the impact of the epidemic, customs clearance at Youyi Port has remained relatively efficient,” said Su, adding that with the support of local customs and other departments, goods from China can be delivered to Bangkok in four or five days.

Su is quite optimistic about the development prospects of the company. “Now China and the ASEAN have become each other’s largest trading partners and the Regional Comprehensive Economic Partnership agreement has also officially come into effect, so we are expecting to enjoy closer regional economic and trade exchanges,” said Su.


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The Perils of Conflicting Economic Sanctions for Multinational Companies

The globalization of business means that many companies operate in more than one jurisdiction. This requires multinational companies to be aware of trade laws in several jurisdictions, e.g., regarding export control laws and economic sanctions regimes. When a jurisdiction’s laws apply extraterritorially or regimes conflict, companies are left wrestling with whether to proceed with certain transactions. This is particularly true in relation to the economic sanctions regimes in the European Union and the United States. For companies subject to U.S. economic sanctions regimes, compliance is complicated by Regulation (EC) No 2271/96 (EU Blocking Regulation), which was updated in 2018 in light of the U.S. position on Iran. An illustration of this can be found in the recent judgement by the Court of Justice of the EU (CJEU) (Grand Chamber) in Bank Melli Iran v Telekom Deutschland.1

The EU Blocking Regulation

The EU Blocking Regulation intends to “shelter” EU operators from certain U.S. sanctions that have extraterritorial effect.2 The EU Blocking Regulation nullifies the effect in the EU of any foreign court judgements based on such sanctions, allows companies to recover damages arising from these sanctions, and forbids EU operators from complying with such sanctions. Concerning this last aspect, compliance with U.S. economic sanctions is allowed only if authorized by the European Commission (Commission) and where non-compliance “would seriously damage” an EU operator’s interests or those of the EU.3 In practice, this threshold is difficult to overcome, and – importantly – companies do not want to endanger their dealings in the United States, face significant U.S. enforcement actions, or become the target of secondary U.S. sanctions by breaching any U.S. sanctions programs.

In response to the U.S. withdrawing from the Iranian nuclear deal and re-imposing economic sanctions on Iran, the EU expanded the EU Blocking Regulation to include prohibitions on complying with those sanctions in 2018. Additionally, the Commission adopted Implementing Regulation (EU) 2018/1101 – setting out how to apply for a derogation authorization – and a Guidance Note.

Pursuant to the EU Blocking Regulation, each EU Member State determines the sanctions in the event of breach of the EU Blocking Regulation. Local transposition of this requirement by EU Member States varies. Some have implemented criminal penalties, while others impose administrative fines (e.g., Germany).

The EU Blocking Regulation is currently undergoing a review which may lead to a revision in 2022. A Commission report summarizing the results of the public consultation notes (at p. 3) that the EU Blocking Regulation has been “unsuccessful in achieving its objective of protecting EU operators”, and highlights “the vagueness of the language used”.

Overview of Key U.S. Economic Sanctions

Current U.S. sanctions against Iran stem from a collection of statutes, Executive Orders and implementing regulations. At present, U.S. persons – entities incorporated in the U.S. and their foreign branches, and U.S. citizens or nationals wherever located around the world – are restricted from all direct or indirect dealings with Iran, unless the activities qualify for an exception or exemption or are otherwise authorized by the U.S. government. Complicating matters further, wholly foreign subsidiaries of U.S. persons are likewise prohibited from “knowingly engaging in any transaction, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would be prohibited . . . if engaged in by a United States person or in the United States.” (31 C.F.R. 560.215)

It is this broad reach of U.S. extraterritorial jurisdiction that can create significant a legal and practical conundrum for European subsidiaries of U.S. companies in light of the EU Blocking Regulation.

Illustration: Bank Melli Iran v Telekom Deutschland

Bank Melli Iran (BMI) is a bank owned by the Iranian State, with offices in Germany. Telekom Deutschland GmbH (Telekom) is based in Germany and a subsidiary of Deutsche Telecom AG (DT). DT is a leading telecom company, with its headquarters in Germany. In 2018, DT generated net revenues of € 75.6 billion globally, of which approx. € 36.5 billion in the United States.

BMI and Telekom were contracting parties to an agreement pursuant to which Telekom provided telephone and internet services to BMI. With effect from Nov. 5, 2018, the U.S. re-imposed secondary sanctions against Iran. Those sanctions affected persons covered by the Specially Designated Nationals and Blocked Persons List (SDN List) maintained by the U.S. Office of Foreign Assets Control (OFAC), on which BMI was included. On Nov. 16, 2018, Telekom notified BMI of the termination of the agreement between them with immediate effect. Telekom apparently did not motivate the termination4 and did not have an authorization from the Commission. In turn, BMI initiated legal proceedings in Germany against Telekom seeking an order that the latter keeps all telephone and internet services active. BMI claimed that the termination breached the EU Blocking Regulation.

On appeal, the German court requested the CJEU issue a preliminary ruling concerning the interpretation of the EU Blocking Regulation. In its judgement – its first on the EU Blocking Regulation – the CJEU ruled that it is necessary to consider the principle of proportionality in assessing whether the termination of an agreement in compliance with U.S. economic sanctions must be allowed. In particular, regard should be had for whether forcing the continuation of the agreement could entail disproportionate economic consequences. The CJEU leaves it to the German referring court to assess how to apply proportionality in the case at hand. However, the CJEU noted that one factor that should be taken into consideration is that Telekom had not attempted to apply with the Commission for an exemption from the EU Blocking Regulation before terminating the agreement with BMI.

Contracting Considerations

From a (continental) European point of view, the effect of the EU Blocking Regulation on the contractual obligations as per the applicable substantive law varies with the options and remedies available under that law. Consequently, the contractual provisions should be tailored using the law chosen.

In its judgement in Bank Melli Iran v Telekom Deutschland, the CJEU introduces an extra-contractual balancing test that focuses on proportionality. To assess the proportionality of the effect of the EU Blocking Regulation, the CJEU finds it is necessary to weigh (i) the pursuit of those objectives served by the annulment of a termination in violation of the prohibition laid down in Article 5(1) of the EU Blocking Regulation, and (ii) the probability that the party concerned may be exposed to economic loss, as well as the extent of that loss, if it cannot terminate its commercial relationship with a U.S. sanctioned person.

This results in a double test to be conducted post factum which leaves the contracting parties with a large degree of uncertainty – also because the balancing test seems to exclude that nullity or annulment can be claimed of the obligations entered into because performance would result in a breach of law and regulations. Where the performance of an obligation breaches the law, that claim would typically not be available; however, an agreement breaching U.S. sanctions does not result in the performance being in breach of law or public order in Europe.

For agreements that existed prior to the U.S. extraterritorial effect of the sanctions, the appearance of such impediments may arguably be considered a force majeure event, which then by definition would be temporary. The effect of the EU Blocking Regulation – which is part of the public order of EU Member States – would then be to qualify the possibility to invoke the force majeure, allowing the contracting party impacted by the sanctions to claim either specific performance or damages. For obligations entered into subsequent to U.S. sanctions, the force majeure cannot exonerate the obliged party, and other contractual remedies are needed, assuming that the EU Blocking Regulation, as interpreted by the CJEU, does not override as public order law such contractual provisions.


The EU Blocking Regulation puts multinational companies in a difficult position, particularly given the permeation of the U.S.’s extended financial networks. Bank Melli Iran v Telekom Deutschland highlights the uncertainties and potential dilemmas faced by EU operators when dealing with persons designated under U.S. economic sanctions covered by the EU Blocking Regulation. Companies are de facto often forced to choose between doing business in the United States and doing business in Iran. And although the CJEU grants weight to the option to seek a waiver, the result of the balancing acts leaves European companies with substantial uncertainty.

As former UK Foreign Secretary Boris Johnson indicated in 2018, it would be very difficult to protect European operators “due to the extra-territorial effect of US sanctions and the difficulty companies have when they touch the live wire of the American financial network and they find themselves almost immediately sanctioned”. Indeed, the EU Blocking Regulation appears generally ineffective when it comes to counteracting the effects of U.S. economic sanctions, and EU operators fear the extraterritorial reach of such sanctions far more than any EU Member State enforcement action.

Nevertheless, the forthcoming revision of the EU Blocking Regulation could be accompanied by a more centralized sanctions and enforcement regime, which may potentially more effectively persuade EU operators to contract with Iranian parties. However, it is also possible that a revision will simply make the balancing and business determination that much more difficult for EU operators. The appetite, resources, and precedent of U.S. sanctions enforcement mechanism is unlikely to be significantly impacted, even by a revised strict EU Blocking Regulation.

On the other hand, given the fluid state of Iran nuclear negotiations, the complexities raised by the EU Blocking Regulation may be temporarily diffused if the United States offers to retract much of the extraterritorial reach of its sanctions regime and the risk of secondary sanctions as part of that negotiation process. 

1 Case C-124/20, Bank Melli Iran v Telekom Deutschland GmbH, judgement, Dec. 21, 2021.

2 See Annex to the EU Blocking Regulation.

3 Article 5, para. 2 of the EU Blocking Regulation.

4 We do not know whether Telekom’s concern was prompted by U.S. enforcement action, or the risk of secondary sanctions – i.e., Telekom itself being listed for dealing with BMI. Based on publicly available information, our understanding is that Telekom was and is 100% owned by DT. If this understanding is accurate, there would not be direct liability under 31 C.F.R. 560.215, as Telekom is not owned or controlled by a U.S. person.

©2022 Greenberg Traurig, LLP. All rights reserved.
National Law Review, Volume XII, Number 35


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US Counters China’s ‘Economic Coercion’ Against Lithuania in Taiwan Dispute 

A senior U.S. delegation visited Lithuania this week in a show of support for the Baltic state in its growing dispute with China involving Taiwan.

Beijing effectively blocked imports of Lithuanian goods last month after Taiwan was allowed to open a representative office in the capital, Vilnius. China claims Taiwan as part of its territory. The dispute has rapidly escalated into a trade tussle between the West and Beijing.

Jose W. Fernandez, undersecretary for economic growth, energy and the environment, met Lithuanian government ministers in a visit described by the U.S. State Department as showing “continuing strong support for Lithuania in the face of political pressure and economic coercion from the People’s Republic of China.” The two sides discussed the implementation of a $600 million agreement on boosting trade.

Lithuania welcomed the intervention. “We permanently feel U.S. strong political and practical support in our dispute with China over its systemic violations of international trade rules,” the Ministry of Foreign Affairs said in a press release.


The dispute began in 2020 when Lithuania’s new government pledged to support what it called “freedom fighters” in Taiwan and criticized Beijing’s human rights record in Hong Kong and Tibet.

In May 2021, Lithuanian lawmakers approved a resolution that described China’s treatment of its Uyghur minority as “genocide.” China has rejected such accusations.

In November of last year, Taiwan officially opened the representative office in Vilnius. Its director, Eric Huang, said the goal was the “strengthening of [the] bilateral relationship comprehensively between Taiwan and Lithuania.”

Lithuania said the opening did not affect its policy toward China or imply any official recognition of Taiwan as independent from Beijing. The move, however, stoked fury in Beijing.

“From the perspective of Beijing, it’s crossing a line, a real red line on how they approach Taiwan. And this is what led later to Beijing downgrading its embassy in Lithuania,” Grzegorz Stec of the Berlin-based Mercator Institute for China Studies said in a recent interview with VOA.

Import blockade

In December, China effectively blocked Lithuanian imports by delisting it as a country of origin, meaning goods can’t clear Chinese customs, while pressing multinational businesses to sever ties with the Baltic country.

“And that works not only in some cases for goods that are produced in Lithuania but also goods that include in their supply chain components produced in Lithuania. Also, the European exports that have been transited through Lithuanian ports, they have also been affected,” Stec said.

FILE – EU Trade Commissioner Valdis Dombrovskis speaks during a press conference in Brussels, on Dec. 7, 2021.

EU challenge

The European Union accuses China of threatening the integrity of its single market and has launched a challenge at the World Trade Organization.

“We are stepping forward to defend the EU’s rights,” EU Commission Executive Vice President Valdis Dombrovskis told reporters January 27.

“Since December 1, Chinese customs are banning Lithuanian imports from the Chinese market. … Chinese companies are canceling orders from Lithuania. China is also cutting its exports to Lithuania. Moreover, China is putting pressure on international companies to abandon the use of Lithuanian components in their production,” Dombrovskis said.

It likely will take years for the WTO challenge to be resolved. In the meantime, the EU is working on legal instruments to counter coercive practices.

“This could include really targeting or restricting access for companies from a specific country from the single market. Right now, we don’t really have a clear instrument for doing that,” Stec told VOA.

Lithuanian lifeline

The Taiwan government has offered Lithuania a $1 billion credit program and a separate $200 million fund to boost trade. Lithuania has donated hundreds of thousands of COVID-19 vaccines to Taiwan.

The United States has also stepped in to make up the shortfall caused by China’s blockade. The U.S. Export-Import Bank signed a $600 million export credit agreement with Lithuania, focusing on manufacturing, business services and renewable energy.

But it’s not just about money, Stec said. “Symbolic involvement [by the U.S.] of course supports Lithuania by showing that it’s not isolated in its moves. At the same time, it also makes it harder to unravel the situation because it once again puts it in the spotlight.”

U.S. officials also held talks in Brussels on joint measures to tackle economic coercion.

FILE - Chinese Foreign Ministry spokesman Zhao Lijian gestures as he speaks during a daily briefing at his ministry in Beijing, Feb. 24, 2020.

FILE – Chinese Foreign Ministry spokesman Zhao Lijian gestures as he speaks during a daily briefing at his ministry in Beijing, Feb. 24, 2020.


China, meanwhile, accuses Lithuania of “betrayal.”

“The issue between China and Lithuania is a bilateral issue between China and Lithuania, not between China and Europe. We urge Lithuania to correct its mistakes immediately, and not act as a pawn of Taiwan independence separatist and anti-China forces. We also remind the EU to distinguish right from wrong and be alert to Lithuania’s attempts to hijack China-EU relations,” Chinese Foreign Ministry spokesperson Zhao Lijian told reporters January 27.


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Moody’s to Acquire Majority Stake in GCR Ratings, Expanding Presence in Africa

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Moody’s Corporation (NYSE: MCO) ( announced today that it has agreed to acquire a majority (51%) stake in Global Credit Rating Company Limited (GCR). GCR is a leading credit rating agency in Africa with operations spanning the continent, including in South Africa, Nigeria, Senegal, Kenya, and Mauritius.

“GCR’s ratings play a significant role in the growth of Africa’s financial markets by providing critical insights into credit across a range of economies and sectors,” said Rob Fauber, President & Chief Executive Officer of Moody’s. “By combining GCR’s successful domestic operations with Moody’s global expertise, we have a unique opportunity to expand Moody’s presence in a high-growth region.”

“This is an important milestone in the history of GCR,” said Marc Joffe, Chief Executive Officer of GCR. “This transaction will enable us to build on our deep local market insights and a quarter-century of growth across the continent. It will also provide the opportunity to further develop solutions that meet a range of customer needs, including credit ratings, credit risk solutions, and ESG capabilities.”

Moody’s is committed to economic transformation in South Africa and sees empowerment as an important part of the future success of its investment in GCR. To this end, Moody’s is engaging with a South Africa-based empowerment partner who will provide local strategic support through substantial equity participation and representation on the GCR South Africa board.

Moody’s and GCR are also committed to playing a positive societal role. In South Africa, Moody’s and GCR intend to advance corporate social responsibility initiatives, including social enterprises that provide education and support to female-owned businesses and entrepreneurs.

Following the transaction, GCR will continue to develop its own rating methodologies, issue its own credit ratings, and maintain a separate management team.

The transaction is subject to customary regulatory approvals. The terms of the transaction were not disclosed, and it will be funded with cash on hand. The transaction is expected to close in Q2 2022 and will not have a material impact on Moody’s 2022 financial results.  

Distributed by APO Group on behalf of Moody’s Corporation Investor Relations.

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About Moody’s Corporation:
Moody’s (NYSE: MCO) is a global integrated risk assessment firm that empowers organizations to make better decisions. Its data, analytical solutions, and insights help decision-makers identify opportunities and manage the risks of doing business with others. We believe that greater transparency, more informed decisions, and fair access to information open the door to shared progress. With over 13,000 employees in more than 40 countries, Moody’s combines international presence with local expertise and over a century of experience in financial markets. Learn more at

“Safe Harbor” Statement Under the Private Securities Litigation Reform Act of 1995:
Certain statements contained in this document are forward-looking statements and are based on future expectations, plans and prospects for Moody’s business and operations that involve a number of risks and uncertainties. The forward-looking statements in this document are made as of the date hereof, and Moody’s disclaims any duty to supplement, update or revise such statements on a going-forward basis, whether as a result of subsequent developments, changed expectations or otherwise. In connection with the “safe harbor” provisions of the Private Securities Litigation Reform Act of 1995, Moody’s is identifying certain factors that could cause actual results to differ, perhaps materially, from those indicated by these forward-looking statements. Those factors, risks and uncertainties include, but are not limited to the impact of COVID-19 on volatility in the U.S. and world financial markets, on general economic conditions and GDP in the U.S. and worldwide, and on Moody’s own operations and personnel; future worldwide credit market disruptions or economic slowdowns, which could affect the volume of debt and other securities issued in domestic and/or global capital markets; other matters that could affect the volume of debt and other securities issued in domestic and/or global capital markets, including regulation, credit quality concerns, changes in interest rates, inflation and other volatility in the financial markets such as that due to Brexit and uncertainty as companies transition away from LIBOR; the level of merger and acquisition activity in the U.S. and abroad; the uncertain effectiveness and possible collateral consequences of U.S. and foreign government actions affecting credit markets, international trade and economic policy, including those related to tariffs, tax agreements and trade barriers; concerns in the marketplace affecting our credibility or otherwise affecting market perceptions of the integrity or utility of independent credit agency ratings; the introduction of competing products or technologies by other companies; pricing pressure from competitors and/or customers; the level of success of new product development and global expansion; the impact of regulation as an NRSRO, the potential for new U.S., state and local legislation and regulations; the potential for increased competition and regulation in the EU and other foreign jurisdictions; exposure to litigation related to our rating opinions, as well as any other litigation, government and regulatory proceedings, investigations and inquiries to which Moody’s may be subject from time to time; provisions in U.S. legislation modifying the pleading standards and EU regulations modifying the liability standards, applicable to credit rating agencies in a manner adverse to credit rating agencies; provisions of EU regulations imposing additional procedural and substantive requirements on the pricing of services and the expansion of supervisory remit to include non-EU ratings used for regulatory purposes; the possible loss of key employees; failures or malfunctions of our operations and infrastructure; any vulnerabilities to cyber threats or other cybersecurity concerns; the outcome of any review by controlling tax authorities of Moody’s global tax planning initiatives; exposure to potential criminal sanctions or civil remedies if Moody’s fails to comply with foreign and U.S. laws and regulations that are applicable in the jurisdictions in which Moody’s operates, including data protection and privacy laws, sanctions laws, anti-corruption laws, and local laws prohibiting corrupt payments to government officials; the impact of mergers, acquisitions or other business combinations and the ability of Moody’s to successfully integrate acquired businesses; currency and foreign exchange volatility; the level of future cash flows; the levels of capital investments; and a decline in the demand for credit risk management tools by financial institutions. Other factors, risks and uncertainties relating to our acquisition of RMS could cause our actual results to differ, perhaps materially, from those indicated by these forward-looking statements, including risks relating to the integration of RMS’s operations, products and employees into Moody’s and the possibility that anticipated synergies and other benefits of the acquisition will not be realized in the amounts anticipated or will not be realized within the expected timeframe; risks that the acquisition could have an adverse effect on the business of RMS or its prospects, including, without limitation, on relationships with vendors, suppliers or customers; claims made, from time to time, by vendors, suppliers or customers; changes in the U.S., Europe (primarily the U.K.), Japan, India or global marketplaces that have an adverse effect on the business of RMS. These factors, risks and uncertainties as well as other risks and uncertainties that could cause Moody’s actual results to differ materially from those contemplated, expressed, projected, anticipated or implied in the forward-looking statements are currently, or in the future could be, amplified by the COVID-19 outbreak, and are described in greater detail under “Risk Factors” in Part I, Item 1A of Moody’s annual report on Form 10-K for the year ended December 31, 2020, and in other filings made by Moody’s from time to time with the SEC or in materials incorporated herein or therein. Stockholders and investors are cautioned that the occurrence of any of these factors, risks and uncertainties may cause Moody’s actual results to differ materially from those contemplated, expressed, projected, anticipated or implied in the forward-looking statements, which could have a material and adverse effect on Moody’s business, results of operations and financial condition. New factors may emerge from time to time, and it is not possible for Moody’s to predict new factors, nor can Moody’s assess the potential effect of any new factors on it.

This Press Release has been issued by APO. The content is not monitored by the editorial team of African Business and not of the content has been checked or validated by our editorial teams, proof readers or fact checkers. The issuer is solely responsible for the content of this announcement.


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