Q&A: The Bottom Line of Russian Sanctions’ Impact on AML for Private Funds

Proskauer Rose LLP
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Earlier this spring, following the Russian invasion of Ukraine, the Biden administration issued a series of executive orders imposing strong sanctions against Russia. Over the last few months, those sanctions have continued to expand, with OFAC, as well as sanctions authorities in the UK and EU, issuing dozens of new sanction regulations that impact countless segments of the global economy. Those sanctions have had a ripple effect across the investment industry, reshaping AML standards and practices for fund managers and their LPs. Below, we have presented a collection of questions and answers addressing some of the more meaningful aspects that impact fund managers today.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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