US Sectoral Sanctions

US Direct Sanctions - SDNs (cont'd) Other Notable SDN Designations Further 2015-20 SDN designations - persons / companies under EOS 13661, 13662, etc. - including against: Several more Russian officials in connection with the Ukraine/Russia Kerch Strait incident, Russian defense industry enterprises and four entities operating in Crimea, and some for alleged election interference operations Some coordinated with similar EU and Canada actions 2018 addition of several Russian companies (including Power Machines) and officials involvement in transfer of turbines made by a Siemens Russian JV co. to Crimea Sept. 2019 designations of employees of already blacklisted Internet Research Agency (IRA), private jets and yachts of Evgeny Prigozhin (also an SDN already) and his front companies that allegedly finance IRA, under related Trump EO re election interference (see slide 46) Dec. 2019 and Oct. 2020 cyber-criminal designations (re malware infesting financial institutions and industrial safety systems worldwide) Jan. 2020: further individuals in Crimea, and rail carrier running to Crimea across new bridge And July 2020: three individuals and five entities involved in furthering financier Prigozhin's operations in Sudan and assisting his ability to evade sanctions (and related 23 Sept. 2020 designation - see slide 9) Also several Crimean commercial port and transport companies (and some Russian ships that call in Crimea), companies involved in the Kerch Strait and other Russia / Crimea transport projects, banks and resort complexes are also named And a number of Russian defense industry companies (as supplemented April 2018) Including Rosoboronexport (ROE - Russia's giant arms-export enterprise, a sub of Rostec... an existing SSI per OFAC Directive 3 and on LSP) - and ROE's sub Russian Financial Corp (RFK Bank) And note a COVID-19 / Russia sanctions link: April 2020 report that the USG purchased a large shipment of ventilators, face masks etc. from KRET, another Russian SDN subsidiary of Rostec And note Nov. 2018 SDN designations of three human rights abusers (two people and an entity) per CAATSA section 228 And June 2017 (Independent Petroleum Co. - NNK, and a sub.) for dealings with North Korea - but now delisted as of March 2020 (see slides 10 and 36) Morgan Lewis 41

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