Sanctions 101: How Sanctions Regimes Work 

The latest round of sanctions imposed against various Russian individuals, entities, activities and sectors is not a novel development, but the breadth of the sanctions and the global coordination in imposing them does distinguish them from prior iterations. This first article in a three-part series explains how sanctions regimes work. The second article will discuss how sanctions can impact investors and investments – including what to do if an investor or investment is subject to sanctions – while the third article will explore what managers should do to ensure they comply with sanctions and have sufficient protections in their fund documents. See “Quad/Graphics Self-Reports FCPA and Sanctions Violations, Earning a DOJ Declination and Small SEC Fine” (Oct. 16, 2019).

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