Given the likelihood of aggressive sanctions enforcement – and the serious civil and criminal penalties for violations of sanctions – it is critical for private fund managers to ensure they comply with any sanctions that implicate their investors, investments or both. This article, the second in a three-part series, discusses how sanctions can impact a private fund manager’s investors and investments, including what to do if an investor or investment is subject to sanctions. The first article
explained how sanctions regimes work. The third article
will explore what managers should do to ensure that they comply with sanctions and have sufficient protections in their fund documents. See “Navigating an Aggressive AML and Sanctions Enforcement Environment: Risks and Frameworks
” (Jan. 20, 2021).