Secondaries are often criticised because it is just one fund selling to another. Europe’s largest asset manager went so far as to call such arrangements a ‘Ponzi scheme’ of one fund selling to another at inflated prices, without the check of a strategic buyer. On paper, circular deals are even more problematic, as the involved parties are related or sitting on both sides of the negotiation table. This panel will identify the types of transactions and the fact patterns that should trigger the enhanced scrutiny of a deal lawyer, and it will discuss possible ways to properly address these issues.