US Sectoral Sanctions

CAATSA / Guidances / Lists (cont'd) - Mixed messages from Trump Administration upon/since release of those Jan. 2018 Report / Lists But the April 2018 SDN individuals designations came from among those on the Jan. 2018 List (and there have since been some threats of more, including per the proposed DASKA Act if ever enacted) And subsequent public news reports and further private sense that some leading oligarchs have been restructuring holdings to reduce potential or actual sanctions exposure and a number of state / "parastatal" companies are making preparations for possible further sanctions imposition And a few legal challenges against inclusion on this List (e.g., successful Gapontsev case - slide 36) Bottom-line note: companies considering dealing with any individuals or entities on these lists should have in mind the additional risks / due diligence concerns raised, and proceed with caution And companion January 2018 report to Congress on the Effects of Expanding Sanctions to include Russian Sovereign Debt and Derivative Products (per CAATSA sec. 242) - Had an unclassified main text; not clear if it also had a classified annex Did not recommend in favor of such sanctions expansion (given the effects this would have on the ban on US and European, as well as the Russian, financial markets) But note that a limited version of this sanction - ban on US banks' participating in primary market for Russian non-ruble sovereign debt - is one of the CBW Act second-round measures in 2019 (see slides 67-68 below) This limited Trump Administration measure has so far served to forestall Congressional appetite for possible broader Russian sovereign debt ban (but more may now be brewing - see slide 6 above) Morgan Lewis 57 7

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