Morgan Lewis US and Russia Sanctions Update
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 (as does US OFAC Directive 1)
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
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