US Sectoral Sanctions

EU Crimea Sanctions Reg. No. 692/2014 as amended Bars sale, supply, transfer, export of goods and technology (per this Reg's Annex II) to any Crimean entity or individual or for use there Covers oil & gas / other mineral resources and E&P, transport, telecoms, power sectors And further general ban on financing, corporate acquisitions, JVs, investment in real estate, construction / engineering services, investment services, tourism services And see EU Information Note to EU Business Operating and/or Investing in Crimea / Sevastopol (Joint Working Doc. SWD/2014) of July 2014 As amended August 2014, June 2015 and most recently Jan. 2018 Gives updated summary of restrictions now in effect for EU-connected commercial activity there (though no real interpretive guidance) And EU's Sept. 2017 blacklist reg. (see next slide) amendment to allow member state authorities to permit certain types of payments to Crimean Sea Ports Note the still-reverberating 2017 scandal re Siemens gas turbines that found their way to Crimea (evidently without the company's knowledge and despite its compliance program / efforts) And NL-based Booking.com's 2018 announced discontinuance of tourist booking for Crimea Some new EU designations in March 2019 following the Russia-Ukraine Black Sea naval incident, and in Jan. 2020 in connection with Crimean elections Morgan Lewis 81

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