In the final installment of a series by Hedge Fund Law Report on sanctions compliance, partner Giovanna Cinelli discusses the elements of effective sanctions compliance, highlighting the need for due diligence, among other insights and recommendations.
“It’s essential to have a very strong foundation at the start of your engagement with an investor because without adequate information, you’re going to be standing on sand,” said Giovanna.
“The diligence process needs to expand a bit more, from both an information-collection perspective as well as the adequacy of the representations or certifications from investors.”
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