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.
The Executive Orders (EOs) governing these designations (EO
13661 and EO 13662), in addition to prohibiting any
"dealings," also require that US persons
"block" any assets of the SDNs under the US persons'
control, to the extent that those assets are subject to US
jurisdiction. This mandate effectively prohibits any US person from
trading in the securities of the blocked entities or receiving any
payments or proceeds from them.
