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When it comes to sanctions, PE firms must proceed with great caution



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Snežana Gebauer
Contributor

Snežana Gebauer, a partner with StoneTurn, has 20 years of experience in managing complex international investigations for major law firms, Fortune 500 corporations, government agencies and sovereign nations.

The economic sanctions that have been imposed following the war in Ukraine pose an intricate set of challenges for private equity (PE). Sanctions are driven by foreign policy and national security officials rather than regulators, so the landscape can change quickly and in the most unpredictable ways.
Given the multiple waves of sanctions imposed in recent months, PE firms need to be especially vigilant about ensuring their investors have not become subjects of the newly imposed sanctions. If it happens to be so, PE firms will have to navigate the complexities involved in removing sanctioned investors from their funds.
After 9/11, the U.S. passed sweeping anti-money laundering (AML) legislation, requiring all financial institutions to understand who their customers really are. Shortly thereafter, the Treasury Department granted exemptions to certain categories of financial institutions, including hedge funds and PE. These exem …

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