OFAC Regulation of Portfolio Management and Custody

01/23/2015 - 12:00 PM to 1:00 PM
This brown bag will examine the range of practical questions and challenges associated with the application of economic sanctions law to the activities of fund and separate account portfolio management. Topics will include: The different layers of investment prohibitions under the four Directives in the Ukraine-Related Sanctions Regulations; How to apply different types of OFAC country sanctions program to U.S. investment activities; Whether and how sanctions programs can apply to offshore subsidiaries and affiliates of U.S. asset managers; Understanding how the “facilitation” doctrine under the International Emergency Economic Powers Act (IEEPA) can impact investments in securities issued by “third country” companies; ...
+ Read More