In the latest On Track, Houston Partner Brent Shultz and Dallas Partner Robert Bruner discuss how ongoing sanctions levied against Russia following its invasion of Ukraine have impacted hedge funds and private equity funds, which often count Russian oligarchs as investors. Brent and Robert discuss the impact of sanctions on subscription credit facilities; the sort of due diligence that fund managers and subscription lenders perform into investors of funds; the challenges of determining if a particular investor is in fact on a sanctions list; and the steps that funds should take if they determine that an investor is on a sanctions list. A partner in the firm’s Fund Finance Practice, Shultz has negotiated and closed billions of dollars of complex debt financings. Bruner, a partner in the Investment Management Practice, regularly advises private equity and hedge funds in connection with the formation and operation of the funds.