Morgan Lewis US and Russia Sanctions Update

US Direct Sanctions - SDNS Specially Designated Nationals (SDN) List Intro / Basics Based on EOS 13660 and 13661 of March 2014, etc. These are the US "direct" sanctions (as opposed to the SSI "sectoral" sanctions) - All US persons' dealings with - including payments to or receipt of goods / services from - individuals or company SDNS (and subsidiaries) are generally prohibited, and US persons must block their assets Absent applicable general or specific license from OFAC (see slides 38 and 43 below) Possible further penalties - essentially same as above for other OFAC (and BIS) sanctions violations Plus risk of application of CAATSA-based secondary sanctions - see slides 46-59 below Against non-US companies/ individuals that initiate or continue dealings with designated SDNs ("for knowingly facilitating significant transactions for or on behalf of" them - per OFAC April 2018 release) See also OFAC FAQS 574, 579, 580, 589, 590 and 627 - and see generally slides 57-58 below Note: there have been some CAATSA-based SDN designations to date (including Russian companies and individuals in the cyber sector) SDN Individuals Some industry executives / oligarchs have been on OFAC's SDN list since 2014 (and then expanded further in 2015-20) - most notably Initially Messrs. Sechin, Timchenko, Rotenberg - and then Technopromexport's CEO (per the Siemens turbines scandal of 2017); and another Kremlin insider Yevgeniy Prigozhin in 2016 April 2018 dramatic expansion: including Messrs. Deripaska (control of RUSAL, En+, Basic Element, GAZ Group, etc.), Vekselberg (controls Renova, etc.), Miller (Gazprom CEO), Kostin (VTB CEO), Bogdanov (Surgutneftegaz CEO) and Kerimov These designations followed the US Treasury Dept. CAATSA sec. 241 Report to Congress listing many of Russia's senior political figures, oligarchs, and "parastatal entities" (see slides 55-56) And in Feb. 2020 Didier Casimiro, CEO of simultaneously SDN-designated Rosneft Trading S.A. (and he's now a Rosneft SVP), under Venezuela sanctions Some fear in early 2021 of further leading oligarch designations in connection with Navalny events, but hasn't happened yet (though could still) - see slides 5 and 70 Morgan Lewis 33

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