ESMA publishes a Public Statement addressed to Fund Managers in light of the impact of Russia’s Invasion of Ukraine on Funds under Management

On the 16th May, 2022, the European Securities and Markets Authority (“ESMA”) published a public statement entitled, “Actions to manage the impact of the Russian invasion of Ukraine on investment fund portfolios” (“Public Statement”). The Public Statement seeks to guide investment fund managers (predominantly Alternative Investment Fund Managers and UCITS Managers) on the steps they should consider taking to manage the impact on funds under management caused by the Russian invasion of Ukraine.

The Public Statement delves into two key points that fund managers should keep in mind in this context:

  • the manner in which fund managers are to deal with material liquidity issues and valuation uncertainties of assets forming part of fund investment portfolios; and
  • the possibility of creating side pockets within existing funds under management (a measure which allows illiquid assets to be separated from remaining liquid assets within an investment fund).

While we encourage you to access the Public Statement for further information, please feel free to reach out to André Zerafa (, James Farrugia ( or Luigi Farrugia ( should you require any assistance or additional information in relation to the contents of the Public Statement or its implementation in practice.