Morgan Lewis US and Russia Sanctions Update

US Direct Sanctions - SDNs (cont'd) SDN Companies • Dramatic SDN company designations of April 2018 (and wind-down periods, including several successive extensions, set by General Licenses (GLS) for dealings with them), including - - En+, RUSAL, Basic Element, GAZ Group, EuroSibEnergo, Russian Machines, others (linked to Mr. Deripaska) Renova (linked to Mr. Vekselberg) As well as any other companies ultimately owned ≥50% by any of the SDN individuals These designations hit hard - for the first time in the heart of Russia's private-sector economy More still to come from the Jan. 2018 "Oligarchs List"? (depends on ongoing course of US-Russia events) - nothing more yet... though again, could come as part of further Biden Admin. sanctions Then OFAC's SDN delisting of Deripaska-controlled companies - RUSAL, En+, EuroSibEnergo In Jan. 2019 per OFAC Update - Benefited these three companies and their subsidiaries - but Mr. Deripaska himself (and any company he continues to hold ≥ 50% of) remain as SDN per his April 2018 designation Followed the three companies' petition to OFAC (per 31 CFR § 501.807) and months-long negotiation (and several related General Licenses / extensions during that period - see slide 38), and based on a set of strict restructuring and governance change undertakings And these companies are subject to redesignation if any of the agreed terms are violated See slides 40-42, presenting several more Russia-related SDN designations in various categories - which may be less directly important to most business but should be kept in mind Morgan Lewis 35

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