Navigating Sanctions Regimes: U.S. and U.K. (Part One of Two)

Economic sanctions can range from broad national embargoes to targeted measures against individuals and economic sectors. Private fund managers may inadvertently run afoul of U.S. and foreign sanctions regimes by accepting investments from sanctioned persons or by investing in sanctioned entities. A panel at the Seward & Kissel 2020 Private Funds Forum examined navigating various sanctions regimes. The program featured Bruce G. Paulsen, partner at Seward & Kissel; Stephen Gentle, partner at Simmons & Simmons; and Cherie Spinks, counsel at Simmons & Simmons. This article, the first in a two-part series, covers the panelists’ discussion on the nature and extent of the U.S. and U.K. sanctions regimes. The second article will feature the discussion on the E.U. sanctions regime; recent developments in U.S. sanctions against Iran, Venezuela and China; and issues that sanctions regimes pose for investment managers. See “FBI Sees Significant Risk That Private Funds Are Used for Money Laundering” (Sep. 24, 2020).

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