US Sectoral Sanctions

EU Sectoral Sanctions (cont'd) Finance - for Russian Banks Prohibits (per Reg. art. 5.1) purchase or sale of, provision of investment services for or assistance in the issuance of, or other dealings with, "transferable securities" or money-market instruments issued by the 5 Russian banks designated in Annex III (Sberbank, VTB, Gazprombank, VEB, Rosselkhozbank - Russian Agricultural Bank) or their non-EU subs (>50% owned) so, essentially the same coverage as the US OFAC sanctions or persons or entities acting on their behalf or at their direction Applies to debt securities issued (i) 2 Aug. 12 Sept. 2014, with maturity >90 days; and (ii) after 12 Sept. 2014, with maturity >30 days (note OFAC Directive 1 now is = 14 days max.) and to equity securities issued after 12 Sept. 2014 See EU Guidance Note FAQS 33-34, addressing what EU subs of targeted Russian bank entities can / can't do (including warning re passing on funds = circumvention) Morgan Lewis 76

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