Share sales16 Dec 2024 08:20
See below from the FCA handbook - so at a stretch - if Milkwood have sold to cross a shareholding threshold, they have a max of four days (if they claim they did not know for two days the trade had happened - which seems unlikely!) The day with big trades a week ago (9 million or so) would definitely be caught by this - unless their Cayman registration for the Milkwood Fund means they just ignore the rules!
The notification to the issuer shall be effected as soon as possible, but not later than four trading days in the case of a non-UK issuer and two trading days in all other cases, after the date on which the relevant person:
(1) learns of the acquisition or disposal or of the possibility of exercising voting rights, or on which, having regard to the circumstances, should have learned of it, regardless of the date on which the acquisition, disposal or possibility of exercising voting rights takes effect; or
(2) is informed about the event mentioned in DTR 5.1.2 R (2).
And for the purposes of (1) above a person shall, in relation to a transaction to which he is a party or which he has instructed, be deemed to have knowledge of the acquisition, disposal or possibility to exercise voting rights no later than two trading days following the transaction in question