Investor Presentaiton

UK Sanctions (post-Brexit) (cont'd) New Russia sanctions Guidance of June 2020 - updating original May 2019 guidance, and now with FAQS The FAQS reflect the same points as those comprising the EU Guidance Note last amended 2017 (see slide 18 above), but not as complete coverage With these notable differences banks "payment and settlement services" (i.e., corresponding banking) are construed as "making" or "being part of an arrangement to make" a new loan or credit to a targeted entity (compare UK FAQ 6 with EU FAQ 28) - thus aligning UK's position with the US position (see OFAC FAQ 371) the EU Regulation loan and trade finance sanction exceptions for EU subsidiaries/ trade with the EU are narrowed to UK subsidiaries/trade with the UK - which will require extra care, not to violate either rule in applicable cases Sept. 2020 amended Notice and annexed list of blacklisted persons per EU Council Reg. 269/2014 (see slide 86) Also noteworthy I UK gov't Nov.-Dec. 2020 exchange of letters (inquiry and response) clarifying UK sanctions policy post-Brexit "The Global Human Rights Sanctions Regulations 2020" of July 2020, imposing SDN-like blocking sanctions on initial list of several Russian (and Saudi, Myanmar and North Korean) officials alleged to be involved in gross human rights violations Implementation of Oct. 2020 sanctions against six Russian officials and a chemistry institute for the Navalny poisoning previously enforced under the EU's chemical weapons sanctions regime (see slide 14 above) No newest further 2021 human rights designations yet akin to the US/EU ones re Navalny imprisonment etc., but may come Gov't initiative to crack down on Russian oligarchs' "money laundering" ... with reported further attention to this in Jan. 2021 Morgan Lewis 88

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