At the following hyperlink, please find a document entitled “Non-EU Managers and the SFDR – Who Does it Impact? and How?”, that was prepared by Simmons & Simmons, our investment management alliance partner. This document answers certain key questions on why non-EU managers may need to comply with the EU Sustainable Finance Disclosures Regulation (“SFDR”). Of particular importance, U.S. managers who have notified or registered funds for marketing in the EU under the National Private Placement Regimes will need to update their AIFMD disclosures by March 10, 2021, regardless of whether their fund is an “ESG” fund. For more information relating to the AIFMD, the SFDR, or ESG considerations please feel free to contact your primary Investment Management Group attorney at Seward & Kissel LLP.
