US Sectoral Sanctions
EU Sectoral Sanctions (cont'd)
Loans - for Energy (and Military) Companies and Banks
Prohibits (per Reg. art. 5.3) directly or indirectly making or being "part of any
arrangement to make" new loans / credits with maturity >30 days after 12
Sept. 2014 to any entity covered under the previous two slides - namely
the three Russian energy-sector companies (per Annex VI)
the five Russian banks (per Annex III)
the three Russian military-sector companies (per Annex V)
or their non-EU subs, or persons acting on their behalf or at their direction
And see EU Guidance Note, FAQ 31
rollover of an existing debt is allowed, subject to 30-day maturity restriction
but succession of rollovers each with maturity of ≤30 days may = circumvention
Morgan Lewis
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