The UK Financial Conduct Authority (FCA) has introduced a “side pocket” regime for retail fund assets that are subject to sanctions as a result of the Russian invasion of Ukraine. This new liquidity management regime enables sanctioned assets held by retail funds to be segregated from other fund holdings and managed separately with the view to selling these sanctioned investments. Side pockets have traditionally been used by unregulated funds as a liquidity management tool but this is the first time this tool can also be used by UK retail funds.
The regime was introduced in FCA’s policy statement PS22/8: Protecting investors in authorised funds following the Russian invasion of Ukraine 1 following FCA’s consultation paper CP22/8: Protecting investors in authorised funds following the Russian invasion of Ukraine.2 The rules and guidance are set out...