US Sectoral Sanctions

UK Sanctions (post-Brexit) (cont'd) New Russia sanctions Guidance of June 2020 - updating the 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 And 14 Sept. 2020 amended Notice and annexed list of blacklisted persons per EU Council Reg. 269/2014 (see slide 82) Also new UK gov't exchange of letters clarifying UK sanctions policy post-Brexit (see slide 14) "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 Gov't initiative to crack down on Russian oligarchs' “money laundering” (see slide 14) Morgan Lewis 84

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