US Sectoral Sanctions

Proposed Further US Laws DASKA Act (DASKAA) See the Dec. 2019 amended draft approved by Senate Foreign Relations Committee; and see Senate sponsors' 18 Dec. 2019 statement, and State Dept's 17 Dec. 2019 letter stating Administration's opposing views Now (as of fall 2020) some renewed focus on possibly moving it forward to enactment (see slide 5 above) Would amend/enlarge CAATSA in various ways (incl. enlarging scope of possible secondary sanctions - applicable to non-US persons)... including mandating sanctions against: Russian malicious cyber activities; shipbuilding industry; individuals and parastatal entities thought to be close to President Putin (and their family members, and financial institutions engaging in significant transactions with them) a wide range of Russian domestic energy projects, and global energy projects involving certain Russian companies, including making investments in LNG "export facility located outside of [Russia]" (with low $ thresholds) making investments in energy project (unclear meaning) outside Russia that also has involvement by a Russian parastatal or state- owned/controlled company (where total value of project is >$250 million) that sell, lease, provide to Russia goods, services, technology, financing or support that could directly/significantly contribute to Russia's ability to develop/produce crude oil resources in Russia (including with respect to associated infrastructure) ܀ ܀ excludes maintenance of existing projects USG to issue guidance as to (i) scope/application of the exception, and (ii) listing specific covered goods, services, technology, financing, support US persons' dealing in Russian sovereign debt (this would expand the current limited CBW Act ban re Russia's sovereign debt - see slide 67) Menu of possible sanctions is from existing CAATSA (mainly re commerce in/with US) Further anti-Russia sanctions package proposed in June 2020 by a Task Force of the Republican Study Committee ("RSC" - a national security focused group in the US House of Representatives) Advocates DASKAA enactment and further strengthening of the NS2 sanctions (already well in progress - see slides 5-8 above) And, among other things SDN designation of VEB (Vnesheconombank - already an SSI entity under OFAC Directive 1, see slide 19) sanctions on SWIFT (Society of Worldwide Interbank Financial Telecommunications) until it expels Russia from the SWIFT system designation Russia as state sponsor of terrorism Such proposed measures may seem extreme - but in the current environment this RSC report can't be dismissed as a non- starter And three more proposed new sanctions laws introduced into the US Senate in Sept.-Oct. 2020 - see summary and links at slide 6 above Morgan Lewis 69

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