The Stalin skyscraper in Moscow. Photo by Alex Zarubi on Unsplash.
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Even as limited trading resumed on Moscow’s exchange on Thursday, prospects for emerging market funds exposed to Russia remained cloudy as determining accurate asset values continued to be nearly impossible. Fund managers now await guidance from financial supervisors before taking next steps on suspended funds.

A further analysis of fund data by Investment Officer shows that 145 Luxembourg Ucits funds collectively held more than 9 billion euro in Russian assets at the beginning of this year and are directly affected by the turmoil in Russian markets and the sanctions that followed Russia’s invasion of Ukraine. 

A closer analysis of Morningstar data on 855 global investment funds with an exposure of 5 percent or more to Russia shows that Luxembourg is home to the highest number of Russia-exposed funds, followed by Spain, with 103 funds; the United States, with 100 funds; and South Korea, with 97 funds. The full list includes both emerging market funds with some holdings in Russia as well as funds fully dedicated to Russia.

‘Not just a Luxembourg problem’

Collectively, the 145 Luxembourg-domiciled funds listed in the Morningstar data held Russian assets of 9.19 billion euro at the beginning of this year. Since then, fund managers have significantly divested Russian assets before the war started on 24 February. Trade was suspended for some of these funds at the end of February, said spokespeople for some of the firms affected. Up to date Morningstar data for March is expected next month.

The list of firms managing the Luxembourg funds with the highest exposure in terms of asset values includes the likes of Pictet, Schroders, BlackRock, JP Morgan, Fidelity, East Capital, BNP Paribas, Robeco, Vontobel, Abrdn, Franklin Templeton and Amundi.

“I think that all asset managers will have the same problem for this asset class. It’s not just a Luxembourg problem,” said Corinne Lamesch, chair of the board of directors of Luxembourg asset management industry group Alfi in an interview.

‘Zero, or close to zero’

Pictet’s dedicated Russian Equities fund, for example, has been suspended since 24 February - the day of the invasion - and at that time had a value of 560 million euro, just about half its value at the end of 2021. Russian assets held in Pictet’s other emerging market funds have been written off to “zero, or close to zero”, said a person familiar with Pictet’s funds. 

Spokespeople for several other investment firms, including BlackRock, Abrdn and Fidelity also said the value of their Russian assets in emerging market funds has been set to zero. “It’s the risk you took,” said one person familiar with fund management. 

This valuation decision however becomes more complex when a fund has a significant exposure to Russian assets. Luxembourg’s supervisor CSSF has identified 61 funds whose Russian assets account for 10 percent or more. Two thirds of these funds are equity funds. Trade in these funds remains suspended until supervisors provide clarity on possible next steps. 

Industry experts expect financial authorities such as CSSF and Esma in the next weeks to provide specific guidance on new liquidity tools such as “side pockets” or other segregation techniques so that emerging market Ucits funds with a significant position in Russian assets can resume trading again. 

“It would protect the investors in the current case, because it would isolate a problem,” said Lamesch, referring to possible use of side pockets. “The rest of the fund could live on normally. So it is a very good tool, which we might have underestimated.”

Trade in dedicated Russia funds nevertheless is expected to remain suspended as long as it remains uncertain how the war in Ukraine and sanctions against Russia will develop further. 

Sanctions complicate fund management

What’s more, the international sanctions against Russia add pressure to fund managers, said a leading securities lawyer in Luxembourg.

“With the war between Russia and Ukraine, the impact on funds has been huge, because of  sanctioned investors, because of sanctioned assets in the funds. Some investors would like to get rid of such assets,” said Michèle Eisenhuth, securities law specialist and partner at Arendt & Medernach, one of Luxembourg’s leading law firms. 

“Funds would like to get rid of certain investors. That’s difficult, because in Ucits, in particular, you do not have all the tools right now to properly do things. But the authorities have shown that they are very open to discussion. They have recognised that there is a need to act,” she told Investment Officer.

Luxembourg’s chief financial regulator Claude Marx this week called on investment professionals to make an extra effort to adhere to sanctions and to identify Russian money that may be hidden in funds. “It is very important we make sure that we do not have sanctioned oligarchs investing in funds,” he said at a conference. 

Side pockets as ‘last resort’

The concept of side-pockets, well known for treating illiquid assets in hedge funds, will likely be applied to Luxembourg Ucits funds, although some industry experts believe it may be called ‘split’ or ‘segregation’. Even so, it would allow Russian assets to be placed in a specific sub-section of the emerging market fund.  

“It’s a last resort mechanism,” said Alfi’s Lamesch. “To use this technique, you really need to think it through to the end, because as you know, Ucits funds are broadly distributed. The end investor is not always the first point of contact of the funder intermediaries. So how would you implement this from an operational perspective? That’s another topic we’re discussing.” 

CSSF is expected to attach conditions to the use of such a tool. “A side pocket, that’s a pocket with illiquid assets here, and you know that in Ucits, assets are supposed to be liquid. That’s the concern of the authorities,” said Eisenhuth.

“They recognise that they have to find a solution for the asset manager. That’s just it. We have to solve that issue. We’ll not solve the war but we have to solve that issue.”

With data reporting by Mike Gordon at InvestmentOfficer.lu and reporting by Lenneke Arts at InvestmentOfficer.nl

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