Novel US and EU Sanctions Targeting Russian Financing Activities Raise Unique Compliance Considerations for Global Financial Industry

September 29, 2014

Since March 2014, the United States and EU have imposed multiple rounds of sanctions restricting certain activities with Russian and Ukrainian individuals and companies. The most recent round of sanctions came into effect on September 12, 2014. The nature of these sanctions differs markedly from typical measures used by the United States and the EU in the past, as sanctions previously involved freezing all assets of designated companies and prohibiting all transactions with such entities. In contrast, the United States and EU have imposed targeted measures with respect to Russia that prohibit dealings in specific types of debt and equity instruments of certain Russian entities in specific sectors. These measures present special challenges for the financial industry generally – and for asset managers in particular.

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