US Sectoral Sanctions

What's Newest (cont'd) OFAC 16 July 2020 further general license extensions - and also expansion - to 22 Jan. 2021 on dealings with the major automotive co. GAZ Group (another Deripaska assets) GL 130: for divestment / transfer of debt and equity holdings etc. GL 151: for maintenance/wind-down of pre-existing commercial relations - but also allowing a broad range of new commercial activities with GAZ and its controlled entities (and imposing new regular reporting requirements on GAZ - including monthly certifications that the Group is not acting for or on behalf of Deripaska or other SDN, and that control is in the hands of the Board and shareholders) Also OFAC July 2020 related amendments to several FAQS This may indicate that negotiations for delisting of GAZ (left as SDN when RUSAL, En+ and EuroSibEnergo were delisted in Jan. 2019 – see slide 35) have progressed meaningfully (perhaps as Deripaska decontrol is being worked out or otherwise; see this interesting analysis) Status of challenges to SDN or CAATSA sec. 241 designation of certain "oligarchs" - OFAC notified Mr. Deripaska in Jan. 2020 that he is unlikely to be delisted (see letter and news report), and OFAC formally denied his request in March 2020 (see federal court case current status report) Mr. Vekselberg's delisting application is apparently still pending - and see also the Sept. 2020 decision dismissing US federal court complaint by Vekselberg-associated US investors (more on slide 36) And reported 3 Dec. Swiss court decision rejecting Vekselberg co. claim against bank to unblock USD funds (see slide 60) Jan. 2020 news report of an Asian gov't declining to go forward on a proposed project with a Russian co. - apparently just because its principal is on the Oligarchs List (see slides 56-57) - but most recently reported to be going forward despite this OFAC's March 2020 SDN-delisting of Mr. Khudainatov's NNK and a sub. (had been designated in 2017 for shipping petroleum products to North Korea) Morgan Lewis 10

View entire presentation