PPM redaction is the removal of personal identifiers from a placement memorandum used in a UK private placing. A PPM is a financial promotion, so FSMA 2000 s.21 applies unless an exemption in the Financial Promotion Order 2005 is used, and the placing must stay inside UK Prospectus Regulation Art. 1(4) to avoid the approved-prospectus requirement in FSMA 2000 s.85. anonym.plus marks each principal and contact on your machine, so the offering terms stay whole while private data goes.
When this applies
The memorandum names principals, sets out their track records and gives direct contacts. Those biographies are the most identifying pages in the document. You trim them before the file circulates to prospective buyers.
How anonym.plus handles it
- Open the memorandum in anonym.plus on your device.
- Local OCR reads scanned bio and exhibit pages.
- The tool flags names, contacts, and identifiers.
- Keep the offering terms and risk disclosures.
- Swap or black out the confirmed identifiers.
- Save the clean memorandum locally.
What you need to provide
- The memorandum (PDF, DOCX, or scan).
- An operator (Replace keeps the terms readable).
- Optional name map for principals across drafts.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | principal D. Vance → [PRINCIPAL] |
| Contact | EMAIL_ADDRESS | deal@example.co.uk → [EMAIL] |
| Contact | PHONE_NUMBER | +44 131 496 0782 → [PHONE] |
| Identifiers | UK_NINO | principal NINO → [NINO] |
| Financial | UK_BANK_NUMBER | escrow acct → [ACCOUNT] |
| Location | LOCATION | office address → [ADDRESS] |
Compliance achieved
- A PPM is a financial promotion: FSMA 2000 s.21 applies unless an exemption in the Financial Promotion Order 2005 (arts. 19, 48, 49, 50A) is relied on.
- Staying inside UK Prospectus Regulation Art. 1(4) keeps the placing clear of the approved-prospectus requirement in FSMA 2000 s.85.
- A private company may still not offer its shares to the public — CA 2006 s.755.
- Misleading statements or omissions are an offence under Financial Services Act 2012 s.89, so never cut a material fact to hide a person.
- Offline work keeps the memorandum confidential; AES-256-GCM protects working copies.
Anonymise placement memoranda offline — see plans & start free →
Limitations & cautions
A principal's detailed track record can identify them long after the name is gone — a fund closed in a named year, a single deal, a former employer. The tool flags named items; you review biographies for unique clues. Removing a material fact to obscure a person risks FSA 2012 s.89 exposure.
Frequently asked questions
Will the offering terms survive the pass?
Yes. Allow-list the terms and risk disclosures. Only personal identifiers are flagged for removal.
Does redacting a PPM change who may receive it?
No. FSMA 2000 s.21 and the Financial Promotion Order 2005 decide that, based on the recipient's status, not on the document's contents.
Does the memorandum leave my machine?
No. The app is offline, so the offering stays confidential on your device.