“A lot of the work that I do is historic-the maximum sentences change at different points of time. It's really complicated and people get it wrong all the time. That's when having a timeline is really useful.”
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This Practice Note explains the Financial Conduct Authority (FCA) framework permitting authorised funds to deploy side pockets for assets hit by Russia’s invasion of Ukraine and the ensuing sanctions. It provides questions and answers on this framework, including topics such as: scope initial considerations impact on investors cost considerations alternatives changes to the FCA’s proposed rules any further FCA guidance relating to side pockets and managing side pockets It also highlights initial and ongoing considerations for establishing, operating, and managing side pockets within authorised funds effectively. Background On 6 July 2022, the Financial Conduct Authority (FCA) published policy statement PS22/8, ‘Protecting investors in authorised funds following the Russian invasion of Ukraine’, which outlined urgent measures to manage the invasion’s effects on authorised funds and retail investors. Those rules came into effect on 11 July 2022. That policy statement followed consultation paper CP22/8, ‘Protecting investors in authorised funds following the Russian invasion of Ukraine’, which invited views...