American Club Circular No. 1 1/15 1 FEBRUARY 11, 2015 CIRCULAR NO. 11/15 TO MEMBERS OF THE ASSOCIATION Dear Member: UKRAINE/RUSSIA RELATED ECONOMIC SANCTIONS: CRIMEA REGION OF UKRAINE Further to the observations contained in Circular No. 10/15 of February 10, 2015 concerning PEME clinics in Sevastopol and Kerch, your Managers wish to draw the attention of Members and other concerned persons to US economic sanctions with respect to the Crimea region of Ukraine generally , and to highlight their impact on the American Club and its Members. These sanctions were imposed on December 19, 2014. Brief summary of the Crimea sanctions The US sanctions with respect to Crimea contain provisions concerning the designation of blocked persons or SDNs. This means that transactions with such designated persons (including payments to, or from, them through US banking channels) are prohibited. The SDNs appear on the US Treasury Department, Office of Foreign Assets Control List of SDNs and Blocked Persons. This list may be searched at: https://sdnsearch.ofac.treas.gov/ The sanctions also prohibit the following: (i) new investment in the Crimea region of Ukraine by a United States person, wherever located; (ii) the importation into the United States, directly or indirectly, of any goods, services, or technology from the Crimea region of Ukraine; (iii) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or technology to the Crimea region of Ukraine; and (iv) any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a United States person or within the United States. Impact of the sanctions on cover from the American Club Current US economic sanctions prohibit the American Club from: a. dealing with or engaging in any transaction involving persons blocked by the sanctions with respect to Crimea (SDNs) (see the OFAC SDN List specified above); and b. from providing cover for or other support for Members’ trade with the Crimea region of Ukraine. This includes a prohibition on handling claims involving trade with Crimea. American Club Circular No. 11 /15 2 A copy of the Executive Order imposing US sanctions with respect to Crimea is attached. There exists a general license authorizing the exportation or re-exportation, from the United States or by a US person, wherever located, of agricultural commodities, medicine, and medical supplies to Crimea, or to persons in third countries purchasing specifically for resale to Crimea, and the conduct of related transactions, including the making of shipping and cargo inspection arrangements, the obtaining of insurance, the arrangement of financing and payment, shipping of the goods, receipt of payment, and the entry into contracts (including executory contracts). A copy of this general license is also attached. Impact of the US sanctions on Members US Person Members Unless falling within the authorization under the above-mentioned general license related to exports (from the United States) of agricultural commodities, medicine, and medical supplies to Crimea, US person Members of the American Club are prohibited from trade with Crimea or with SDNs and will have no cover therefor from the American Club. Non-US person Members While the US sanctions with re