A merican Club Circular No . 05/ 23 1 MARCH 6, 2023 CIRCULAR NO. 05/23 TO MEMBERS OF THE ASSOCIATION Dear Member: UNITED STATES AND EUROPEAN UNION IMPOSE FURTHER SANCTIONS ON RUSSIA Significant developments have recently taken place in regard to the application of sanctions against Russia by both the United States and the European Union. US imposes further sanctions against Russia On February 24, 2023, the one-year anniversary of Russia’s invasion of Ukraine, the US Department of State and the US Department of Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on numerous additional individuals, entities and vessels that the US has determined are engaged in sanctions evasion. Full details can be found here. Financial Services Sanctions OFAC designated over a dozen Russian banks and financial institutions, including: • Credit Bank of Moscow Public Joint Stock Company • Joint Stock Company Commercial Bank Lanta Bank • Public Joint Stock Company Commercial Bank Metallurgical Investment Bank (Metallinvestbank) • Public Joint Stock Company MTS Bank • Novosibirsk Social Commercial Bank Levoberezhny Public Joint Company • Bank Saint-Petersburg Public Joint Stock Company • Joint Stock Commercial Bank Primorye • SDM-Bank Public Joint Stock Company • Public Joint Stock Company Ural Bank for Reconstruction and Development (UBRD) • Public Joint Stock Company Bank Uralsib • Bank Zenit Public Joint Stock Company A merican Club Circular No. 05/ 23 2 OFAC also issued a number of general licenses permitting certain transactions in connection with these entities: • General License 8F (replaces GL 8E) was amended to authorize certain energy-related transactions relating to certain of the above-listed financial institutions, until 12:01 a.m. eastern daylight time on May 16, 2023. • General License 13D (replaces GL 13C) authorizes US persons or entities owned or controlled by US persons to carry out certain transactions including paying taxes, fees or import duties and to purchase or receive permits, licenses, registrations, or certificates, that would otherwise be prohibited by Directive 4 under Executive Order 14024, until 12:01 am eastern daylight time on June 6, 2023. • General License 60 authorizes transactions “ordinarily incident and necessary” to wind down transactions involving the above listed financial institutions, until 12:01 am eastern daylight time on May 25, 2023. • General License 61 authorizes transactions “ordinarily incident and necessary” to the divestment or transfer of debt or equity of the above entities, until 12:01 am eastern daylight time on May 25, 2023. Metals and Mining Sanctions OFAC also issued a determination pursuant to Section 1(a)(i) of Executive Order 14024 “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation” (E.O.14024), which enables the imposition of sanctions on individuals and entities who operate or have operated in the metals and mining sector of the Russian economy. Pursuant to this determination, OFAC designated the following four entities: • Joint Stock Company Burevestnik Central Scientific Research Institute • OOO Metallurg-Tulamash • TPZ-Rondol OOO • Mtsenskprokat OFAC has also issued FAQs which provide: - The measures taken by OFAC related to the Metals and Mining Determination, i.e., that parties operating in that sector of the Russian economy can now be designated (FAQ 1114). - The metals and mining sector includes any act o