US Sectoral Sanctions

US Crimea Sanctions Crimea-focused Executive Order 13685 of Dec. 2014 - Bars all new direct or indirect US investments / transactions into Crimea - including for energy sector / offshore areas There are also Jan. 2015 BIS rules implementing this EO (see slide 16) Many Crimea-related SDN designations (entities and individuals) from 2014 to date (slide 41) And March 2020 voluntary disclosure by Swedbank of Crimea-related USD transfers by its Baltic affiliates And July 2020 OFAC Settlement Agreement with world-leading US-based e-commerce co. for deliveries to Crimea etc. (see slide 9) And see July 2015 OFAC Advisory Release re circumvention / evasion by omitting critical information in financial and trade transactions (further to the EO) OFAC warns re various patterns / practices in financial transactions that hinder correspondent banks' efforts to identify and interdict (note the very substantial fines suffered in recent years by various European banks for similar-type violations of OFAC sanctions - against countries other than Russia / Crimea) and similar practices in trade transactions - incl. in distributorship arrangements covering Russia and OFAC advises various types of mitigation measures for these risks Note also these OFAC Crimea-related General License exceptions, including: No. 4 of Dec. 2014, permitting various food and agricultural products (including soft drinks, cigarettes, etc.) and medicines, medical supplies and devices No. 9 of May 2015, permitting common internet communications (see related OFAC FAQ 454) Further SDN designations (somewhat coordinated w/Canada and EU) following 2018 Kerch Strait Ukraine/Russia navies incident: in Sept. 2019, of 3 officers and 5 vessels of already blacklisted Sovfracht and its front co. Maritime Assistance; and in Jan. 2020 (slide 41) Morgan Lewis 46

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