Sanctions 101: How to Comply With Them (Part Three of Three)

OFAC and FinCEN’s recent alerts advising financial institutions to be vigilant about potential Russian sanctions evasion should prompt many to review their companies’ sanctions compliance policies and procedures now to ensure they are up to snuff. This final article in a three-part series explores what fund managers should do to ensure they comply with sanctions and have sufficient protections in their fund documents. The first article explained how sanctions regimes work, and the second article discussed how sanctions can impact a private fund manager’s investors and investments. See “Navigating an Aggressive AML and Sanctions Enforcement Environment: Risks and Frameworks” (Jan. 20, 2021).

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