Morgan Lewis US and Russia Sanctions Update

Proposed Further US Laws (cont'd) And at least three more sanctions bills were introduced in Congress in 2020 (further forward movement only on the second one to date - see slide 6 above) 10 Sept. proposed "Russia Bounty Response Act of 2020" - by Sen. Menendez and five other Democratic senators (keying on the Afghanistan bounty payment allegations, and containing a wide range of proposed sanctions consequences - see press release and full text) 24 Sept. proposed "Holding Russia Accountable for Malign Activities Act of 2020" - by three Democratic senators and Republican Sens. Rubio and Romney (keying on the Navalny poisoning - less elaborate, see press release and full text) 1 Oct. proposed "Safeguarding Elections by Countering Unchallenged Russia Efforts" (SECURE) Act by five House representatives (like DASKAA, would impose broader restrictions on US persons dealing in Russian sovereign debt than are in the current CBW Act (see slides 63-68), including Central Bank or Treasury bonds and certain FX swap agreements - with some exceptions for shortest-term debt (see press release and full text) Further anti-Russia sanctions package proposed in June 2020 by a Task Force of the Republican Study Committee ("RSC" - a national security focused group in the US House of Representatives) Advocates DASKAA enactment and further strengthening of the NS2 sanctions (the latter already well in progress - see slides 5-8 above) And, among other things SDN designation of VEB (Vnesheconombank - already an SSI entity under OFAC Directive 1, see slide 17) sanctions on SWIFT (Society of Worldwide Interbank Financial Telecommunications) until it expels Russia from the SWIFT system designation Russia as state sponsor of terrorism Such proposed measures may seem extreme - but in the current environment this RSC report can't be dismissed as a non-starter Morgan Lewis 70

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