US Sectoral Sanctions

Basic Framework - US/EU (cont'd) European Union • EU Council Reg. No. 833/2014 of 31 July 2014 - as amended and (several times, most recently by Reg No. 2019/1163 of 5 July 2019 Applies to EU nationals and companies Or anything happening in whole or part within EU territory Or involving an EU-registered aircraft / vessel Currently in effect to 31 Jan. 2021 (extended as of 29 June 2020) Commission Guidance Note (16 Dec. 2014, last amended 25 Aug. 2017) on application of certain provisions (the "EU Guidance Note") And SDN-like "blacklist" Reg. No. 269/2014 of 17 March 2014 - And updates since then (incl. re the Siemens turbines scandal and re the Kerch bridge - see slides 82-83) Currently in effect to 15 March 2021 (most recently extended on 10 Sept. 2020) And, re Crimea EU Council Reg. No. 692/2014 of 23 June 2014 - as amended by Reg. No. 825/2014 of 30 July 2014, and Reg. No. 1351/2014 of 19 Dec. 2014 (last extended on 18 June 2020 - now in effect to 23 June 2021) Hits investments in oil & gas and other mineral resources E&P, power, transport, telecoms And further ban on business in various other sectors - see slide 81 for detail EU Council Reg. No. 2018/1542 of 15 Oct. 2018, Concerning Restrictive Measures Against Proliferation and Use of Chemical Weapons; and implementing measures naming Russians as violators (incl. most recent - slide 14) Post-Brexit UK: see slides 71 and 82-83 Morgan Lewis 18

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