Navigating Sanctions Regimes: The E.U. and Hot Sanctions Arenas (Part Two of Two)

Certain countries, individuals and economic sectors can face economic sanctions – such as broad national embargoes or more targeted measures – in response to perceived criminal activity, corruption or human rights violations. Private fund managers should understand the U.S. and foreign sanctions regimes because if they accept investments from sanctioned persons or invest in sanctioned entities, they could be subject to penalties themselves. The Seward & Kissel 2020 Private Funds Forum featured a panel on navigating various sanctions regimes. The panelists included Bruce G. Paulsen, partner at Seward & Kissel; Stephen Gentle, partner at Simmons & Simmons; and Cherie Spinks, counsel at Simmons & Simmons. This article, the second in a two-part series, features the panelists’ 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. The first article examined the nature and extent of the U.S. and U.K. sanctions regimes. For coverage of another panel at the 2020 Private Funds Forum, see “Structural and Operational Considerations for Hybrid Funds” (Jan. 14, 2021).

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