American Club Circular No. 24/14 1 AUGUST 12, 2014 CIRCULAR NO. 24/14 TO MEMBERS OF THE ASSOCIATION Dear Member: EUROPEAN UNION ECONOMIC SANCTIONS: IMPORTS OF GOODS FROM CRIMEA AND SEVASTOPOL Complementing the United States’ imposition of sanctions, and building on various other EU sanctions in response to the situation in Ukraine and Russia’s annexation of the Crimea (e.g., freezing of the assets of designated persons, restrictions on various financial transactions and various dual use and other trade), the EU Council recently published a decision to prohibit the import into the EU of goods originating from Crimea or Sevastopol. The prohibition also extends to the direct or indirect provision of financing or financial assistance, as well as insurance and reinsurance services related to these goods. The Council's decision was formally adopted on June 24, 2014 through Council Regulation (EU) No 692/2014. On July 30, 2014 the EU published Regulation 825/2014 amending Regulation 692/2014. This July 30, 2014 Regulation (“the Regulation”) amends and restates the prohibitions initially announced on June 23, 2014. Prohibitions The Regulation (which entered force on July 31, 2014) prohibits:  The importation into the European Union of goods originating in Crimea or Sevastopol  The provision, directly or indirectly, of financing or financial assistance as well as insurance and reinsurance related to the import of goods originating in Crimea or Sevastopol.  The sale, supply or transfer of designated key equipment and technology for infrastructure projects in the transport, telecommunications and energy sectors.  The sale, supply or transfer of key equipment and technology for the exploitation of oil, gas and mineral resources.  The provision of technical and financial assistance related to the above activities.  The sale, supply, transfer, export, directly or indirectly, of key equipment and technology listed in Annex III to any natural or legal person, entity or body in Crimea or Sevastopol or for use in Crimea or Sevastopol. Additionally:  Contracts entered into before July 30, 2014 (including ancillary contracts) must be executed by October 28, 2014. American Club Circular No. 24/14 2  “Goods” are defined as originating in Crimea or Sevastopol which are wholly obtained in Crimea or in Sevastopol or which have undergone their last substantial transformation there.  The EU’s list of designated goods can be found in Annex III of the Regulation.  “Exploitation” means exploration, prospection, extraction, refining and management of oil, gas, and mineral resources and provision of related geological services but does not include maintenance to ensure safety of existing infrastructure.  The list of designated minerals can be found in Annex II of the Regulation. Regulation 692/2014 of June 23, 2014, as amended, also prohibits the payment of claims in respect of contracts or transactions which are prohibited by the Regulation if they are made by designated persons, entities or bodies listed in Council Regulation 269/2014; persons, entities or bodies acting on behalf of designated entities; persons, entities or bodies who have been found by a competent authority to have infringed the prohibitions in Regulation 692/2014; or if claims relate to the import of goods originating in Crimea or Sevastopol. Exceptions Goods originating in Crimea or Sevastopol which have been made available to the Ukrainian authorities for examination, for which the EU