The Challenge of Protecting Personally Identifiable Information When U.S. Pension Plans Invest in U.K. and Luxembourg Private Funds

Yuliya Oryol wrote “The Challenge of Protecting Personally Identifiable Information When U.S. Pension Plans Invest in U.K. and Luxembourg Private Funds,” which was published in the October 2021 issue of the National Association of Public Pension Attorneys’ monthly newsletter, The NAPPA Report.

In the article, Yuliya examines the steps U.S. public pension plans and other institutional investors must take to verify their identity when investing in funds in certain foreign jurisdictions. The foreign entities generally require prospective investors to submit to background checks and provide personally identifiable information (PII) as part of the due diligence process. However, due to U.S. laws and internal policies, U.S. public pension plans and other institutional investors are unable to publically disclose the PII of their employees and trustees.

Yuliya reviews the underlying legislation in Luxembourg and the U.K. to address what requirements must be met. She then explores how U.S. public pension plans and other institutional investors can satisfy these necessary customer due diligence checks while abiding by U.S. laws and established internal policies.