Scope of Global Sanctions From the Ukraine/Russia War and How Designated Person Standards Affect Fund Managers (Part One of Two)

Outrage over Russia’s invasion of Ukraine garnered a rare consensus in the international community, resulting in a patchwork of sanctions that mostly – but not completely – overlap. The private funds industry has been left to scramble through interpreting those sanctions and nimbly move to remain compliant. In light of those issues, the European Fund and Asset Management Association recently hosted a webinar on the fallout from Russia’s invasion of Ukraine that featured Simmons & Simmons partners Stephen Gentle and Etienne Kowalski, as well as Seward & Kissel attorney Andrew S. Jacobson. This first article in a two-part series discusses various sanctions in the E.U., U.K. and U.S. resulting from Russia’s invasion of Ukraine that affect the asset management industry and some of the consequent compliance challenges facing fund managers. The second article will examine potential environmental, social and governance implications for asset managers; ways that sanctions impact the secondary market and handling of private credit; and potential protections offered by investor treaties. See “How the War in Ukraine is Redefining PE’s Commitment to ESG” (Apr. 19, 2022).

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