US Sectoral Sanctions

EU Direct Sanctions (SDN-like, etc.) • • The EU's SDN-like "blacklist" Reg. No. 269/2014 of March 2014, and with updates And more names have been added in several update regs. to date Individuals and entities, including those added in January 2020, in connection with Crimean elections in March 2019, in connection with the Ukraine/Russia Kerch Strait naval incident in 2018, in connection with construction of Kerch Bridge (to Crimea) in 2017 per the Siemens turbines affair All dealings with the blocked assets of listed persons (or their subs or certain other affiliates) etc. are generally prohibited And see EU Commission Opinion of 19 June 2020 re financial and other transactions with non- blacklisted/designated entities that are owned or otherwise controlled by a blacklisted / designated person per Reg. 269/2014 Note the broad "control" understanding, including management and/or financial control or major influence reflected here) - this ruling not being specific to the Russia sanctions And similar standard at Section 4.1 of UK July 2020 General Guidance Currently in effect to 15 March 2021 (extended as of 10 Sept. 2020) And several Russians (in connection with the 2018 Skripal poisoning in England, and now the Navalny poisoning in Russia) are on the EU's new list of chemical weapons proliferation/use violators - link Morgan Lewis 82 2

View entire presentation