US Sectoral Sanctions

US Direct Sanctions - SDNS (cont'd) Note: the State Dep't Oct. 2017 CAATSA section 231(d) listing of Russian defense / intelligence sector entities (see slide 52), supplemented with 45 more individuals and entities in late 2018 This is the List of Specified Persons ("LSP"): doesn't itself impose SDN (or any other sanctions) on them But many were already SDNS and some were SSIS (including Rosoboronexport - now is both), and there is likely chilling effect in practice on US / other companies' willingness to do business with them (see linked list of them at slide 49), and other companies risk having some SDN-like sanctions imposed on themselves under CAATSA section 235 for some kinds of "significant transactions" with them (see State Dep't announcement (slide 49), and slides 52 and 55) See further discussion on this at slides 52, 54-55 and 59 below And SDN designations of Sept. 2018 - per CAATSA section 231 (defense/intelligence-related) Against EDD (Equipment Development Dep't), a weapons-purchasing entity of the Chinese military - for taking delivery of advanced aircraft and missiles from Rosoboronexport of Russia, which is on the CAATSA section 231 List of Specified Person (LSP), and is also an SDN (see slide 52 below) and EDD's director these were the first-ever SDN designations under CAATSA section 231 (for significant transactions with the Russian defense or intelligence sectors) announced by State Dep't (see the above link - which also set out the specific sanctions chosen and being applied) - and see the corresponding OFAC SDN designations announcement of 20 Sept. 2018 See also new Turkey sanctions mandate in pending NDAA 2021 (section 1241) - for purchase of Russian S-400 air-defense missile system - including statutory finding that this was a "significant transaction" per CAATSA section 231 (see next slide and slide 55) Morgan Lewis 42

View entire presentation