US Sectoral Sanctions

CAATSA / Guidances / Lists (cont'd) - By Presidential Memorandum of Sept. 2017 CAATSA implementation functions were delegated mostly to State and Treasury Dep'ts (and in consultation with Director of National Intelligence) with primary responsibility given to one or the other, on CAATSA article-by-article basis And note EO 13849 of 20 Sept. 2018 setting out certain CAATSA sanctions implementation details for State and Treasury (see slide 58 below) CAATSA also covers Iran and North Korea - introduced stiffened primary and secondary sanctions with regard to those two countries The ever-tightening Iran, North Korea, Venezuela and Syria sanctions, aside from CAATSA, can also continue to affect some Russian (and Chinese) companies, banks, etc. (but those other-countries sanctions regimes are not further covered in this CAATSA summary) e.g., the Feb.-March 2020 SDN'ing of two Rosneft subs. - re Venezuela (see slide 11) and Sept. 2019 SDN designation of two Chinese cos. (and Jan. 2020 delisting of one of them) - re Iran (see slides 11 and 44) see also a July 2020 OFAC Settlement Agreement with a UAE company for trade with North Korea (through Chinese front companies) Also keep in mind potential application of CAATSA secondary sanctions to non-US companies for dealings now barred for US persons under CBW Act second-round sanctions of 2019 - e.g., primary-market purchase of Russian non-ruble sovereign debt, or US bank lending to Russian sovereign (see slides 67-68) the possible further broad expansion of Russia primary and secondary sanctions provisions by the still- proposed DASKA Act which, if ever enacted, would amend CAATSA (see slide 69 below) Morgan Lewis 48

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