Pension Investments: Impacts of the Ukraine / Russia Crisis
Pension scheme trustees will naturally be considering what, if any, steps they may wish to take as the economic effects of Russia’s invasion of Ukraine have begun to be felt worldwide, and as further economic sanctions and restrictions have been imposed on Russia and Belarus.
There are two issues for trustees to consider:
1.whether any of their investments are now subject to sanctions; and
2.whether, in the light of sanctions and the economic and political consequences arising from the Russian invasion of Ukraine, they wish to look again at their investment strategy.
In relation to the first issue, we would recommend that trustees ask their investment managers to confirm to them that none of their funds/portfolios are invested directly or indirectly in entities which are subject to UK, US or EU sanctions. The sanctions net has been drawn widely and it is possible that investments which at first glance seem innocuous have been caught. If an investment has been sanctioned, we would strongly suggest taking specialist advice from our pensions and sanctions teams. This is a complicated and fast-moving area, where getting it wrong could amount to a criminal offence.
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