The Office of Foreign Assets Control recently designated 7 “oligarchs,” 17 government officials, 13 companies, and one bank, all Russian, as Specially Designated Nationals (SDNs), effectively prohibiting US persons (individuals and entities) from any dealings with these SDNs, as well as with entities with 50% or more SDN ownership. Fund investors should be proactive in identifying holdings in blocked entities to avoid inadvertently ending up with interests in blocked assets and the accompanying reporting requirements.
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