Moon Capital Management Lp

Allegations: MOON CAPITAL MASTER FUND LTD. PURPORTEDLY CONTRAVENED ARTICLES 24 AND 28 OF THE TURKISH COMMUNIQUÉ ON MARGIN PURCHASE, SHORT SALE, BORROWING AND LENDING TRANSACTIONS OF CAPITAL MARKET INSTRUMENTS SERIAL V, NO: 65. THESE RULES REQUIRE THE CLEAR IDENTIFICATION OF SHORT SALES BY MARKET PARTICIPANTS, INCLUDING THE INVESTOR AND BROKER EXECUTING ANY GIVEN SHORT SALE. THE ADMINISTRATIVE FINE RELATED TO A SINGLE SHORT SALE TRANSACTION EXECUTED ON JULY 1, 2020. Status: Final Sanction Detail: SEE ITEM 13 BELOW. MOON CAPITAL MASTER FUND LTD. WAS SUBJECT TO AN ADMINISTRATIVE FINE OF TRY 440,226.75 (APPROXIMATELY US$55,515) TO THE CAPITAL MARKETS BOARD OF TURKEY BASED ON ITS FINDING DETAILED IN ITEM 7 ABOVE. THE AMOUNT OF THE ADMINISTRATIVE FINE WAS REDUCED FROM AN INITIAL AMOUNT OF TRY 586,929 (APPROX. US$73,150) BASED ON MOON CAPITAL MANAGEMENT LP'S TIMELY RESPONSE TO THE ANNOUNCEMENT OF THE ADMINISTRATIVE FINE. Summary: THE CAPITAL MARKETS BOARD OF TURKEY DETERMINED THAT MOON CAPITAL MASTER FUND LTD. MUST (I) PAY AN ADMINISTRATIVE FINE OF TRY 440,226.75 (APPROX. US$55,515) BASED ON ITS FINDING THAT MOON CAPITAL MASTER FUND LTD. DID NOT SATISFY THE REQUIREMENTS OF ARTICLES 24 AND 28 OF THE TURKISH COMMUNIQUÉ ON MARGIN PURCHASE, SHORT SALE, BORROWING AND LENDING TRANSACTIONS OF CAPITAL MARKET INSTRUMENTS SERIAL V, NO: 65 IN CONNECTION WITH A SINGLE SHORT SALE TRANSACTION DATED JULY 1, 2020 AND (II) EXERCISE DUE CARE IN CONNECTION WITH ANY FUTURE SHORT SALES. MOON CAPITAL MANAGEMENT LP PAID THE ADMINISTRATIVE FINE ON BEHALF OF MOON CAPITAL MASTER FUND LTD. ON APRIL 14, 2021, AND AS A RESULT, THIS ADMINISTRATIVE FINE DID NOT RESULT IN ANY COST TO MOON CAPITAL MASTER FUND LTD. OR ITS INVESTORS. THE AMOUNT OF THE ADMINISTRATIVE FINE WAS REDUCED FROM AN INITIAL AMOUNT OF APPROXIMATELY US$73,150 BASED ON MOON CAPITAL'S TIMELY RESPONSE TO THE ANNOUNCEMENT OF THE ADMINISTRATIVE FINE.