On 27 September 2022 the Capital Market Authority (“CMA”) of Saudi Arabia announced a series of amendments to its implementing regulations designed to (i) facilitate the direct listing of debt instruments (including convertibles) offered by way of private placement; and (ii) introduce a framework for equity fundraising through crowdfunding platforms. The amended Rules on the Offer of Securities and Continuing Obligations (“OSCOs”) now also provide for the public offer of exchangeable debt instruments. These initiatives…