US Sectoral Sanctions

US Direct Sanctions - SDNs (cont'd) Further recent SDN designations of note affecting Russia - though not under the Russian sanctions regime Trading affiliates of Rosneft: Feb.-March 2020 SDN designations, re Venezuela/PdVSA crude oil business (see slide 11) - Chinese state-owned shipping giant – SDN designations in Sept. 2019 under Iran sanctions regime two specific subsidiaries sanctioned under EO 13846, for shipping Iranian crude oil with a particular Russia-related effect: one of the two sanctioned subs had a venture whose tankers were carrying Yamal LNG product on 31 Jan. 2020 OFAC delisted that sub; thus, no more obstacle to dealing with it (see slide 11) note also related FAQS 804-807 issued in Nov. 2019 (only the first two of which have survived the Jan. 2020 delisting) Two Special Cases - Glavqosekspertiza and FSB Designations / Related GLS Two general licenses issued by OFAC to respond to / correct overbroad reach of the Sept. 2016 and Dec. 2016 designations of GGE and FSB as SDNS (re GGE activities in Crimea and FSB alleged involvement in hacking / election-tampering): OFAC General License No. 11 of 20 Dec. 2016 (entitled "Authorizing Certain Transactions with FAU Glavgosekspertiza Rossii" - GGE) gives general authorization for "all transactions and activities... that are ordinarily incident and necessary to requesting, contracting for, paying for, receiving, or utilizing a project design review or permit from [GGE]'s office(s) in [Russia]" except for carving out (i.e., still prohibiting) anything to do with GGE relating to Crimea OFAC General License No. 1A of (as amended 15 March 2018 to take account of synchronize with CAATSA) under the cyber-related sanctions – entitled “Authorizing Certain Transactions with the Federal Security Service" (FSB) gives authorization for "all transactions and activities... that are necessary and ordinarily incident to ... requesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by [FSB] for the importation, distribution, or use of information technology products in Russia" but export, reexport, or provision of any goods or technology subject to the EAR requires BIS license, and fees payable to FSB shouldn't be ≥$5,000 annually compliance with FSB law enforcement / administrative actions or investigations as well as regulations administered by FSB is authorized Morgan Lewis 44

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