EU sanctions on Russia: targeting key industries

Transcription

1 Ashurst London 1 August 2014 EU sanctions on Russia: targeting key industries In early March 2014, the EU imposed sanctions on a number of Russian and Ukrainian nationals following a referendum in Crimea which led to its disputed unification with the Russian Federation. The number of individuals and companies designated has steadily increased over the last few months, but has not resulted in changes to Russian policy desired by the EU. In response to the recent escalation of Russia's alleged actions in eastern, "sectoral sanctions" have now been implemented which are aimed at restricting certain key industries in Russia's economy. The new sanctions take effect from 1 August Context This briefing focuses on the latest "phase three" sanctions enacted by the EU. Details of the financial sanctions previously imposed are included in our briefing note of 18 March Please click here to view a copy of that briefing. On 31 July 2014, the EU enacted Council Regulation 833/2014 (the Regulation), which came into force on 1 August The Regulation imposes restrictions on the ability of certain state-owned Russian banks to access EU capital markets and on the export of arms, dual-use goods and technology for military use and energy-related equipment and technologies to Russia. A prohibition on the import and export of arms and related materiel to/from Rusia is contained in the accompanying European Council Decision and will be implemented by Member States. Both the United States and the EU have indicated that the scope of the sanctions, and the targets thereof, may be expanded in the future. As the list of designated persons expands, so will the number of businesses and individuals who may be affected. This is a fast-moving area given the ever-changing geopolitical situation. Accurate and up-to-date advice is essential for EU persons and businesses with Russian connections. Overview of the EU/UK sanctions regime The EU imposes sanctions via regulations, which are legally binding in each EU Member State. Each Member State is responsible for the enforcement and administration of EU sanctions and for implementing the penalties for their breach. HM Treasury and the Department for Business, Innovation and Skills are the competent authorities in the UK. EU sanctions are generally targeted against particular individuals, entities or government bodies. The targeted persons are listed in an annex to each regulation that imposes sanctions. However, the new "phase three" or "sectoral sanctions" are aimed at entire sections of the Russian economy. The declared aim of the sanctions is to achieve a political or humanitarian objective by seeking to impose economic leverage on certain decision-makers. We consider below some of the key questions arising from the latest sanctions: 1. What do the sanctions prohibit? The Regulation prohibits the following: (a) the sale, supply, transfer or export to Russia, directly or indirectly, of so-called dual-use goods and technology which may be intended for military use in Russia or for Russian military end-users; (b) the sale, supply, transfer or export to Russia, directly or indirectly, of certain equipment and technology relating to the oil and gas industry without prior authorisation. Technical assistance, brokering services, financing or financial assistance relating to that equipment and technology without prior authorisation is also prohibited; (c) the provision of technical assistance, financing or financial assistance, directly or indirectly, to any AUSTRALIA BELGIUM CHINA FRANCE GERMANY HONG KONG SAR INDONESIA (ASSOCIATED OFFICE) ITALY JAPAN PAPUA NEW GUINEA SAUDI ARABIA SINGAPORE SPAIN SWEDEN UNITED ARAB EMIRATES UNITED KINGDOM UNITED STATES OF AMERICA

2 person or entity in Russia or for use in Russia, relating to military goods and technology. The Regulation also prohibits the provision of technical assistance or brokering services, directly or indirectly, relating to dual-use goods and technology, where the items may be intended for military use in Russia or for Russian military end-users; and (d) EU nationals and companies from buying or selling new bonds, equity, treasury bills or similar instruments, with a maturity exceeding 90 days, issued by certain designated Russian state-owned banks. The prohibition extends to instruments issued by their subsidiaries and persons acting on their behalf. 2. To whom do the sanctions apply? The sanctions restricting financial transactions with Russian state-owned banks apply to: (a) specific entities listed at Annex III to the Regulation. In the Regulation, the named banks are Sberbank, VTB Bank, Gazprombank, Vnesheconombank (VEB) and Rosselkhozbank (the Designated Banks); 4. Who must comply with the sanctions? As is customary, the sanctions are broad in scope and the following are obliged to comply with them: (a) any person inside or outside the territory of the EU who is a national of a Member State, i.e. this extends to any EU nationals who are directors or employees of any company, anywhere in the world; (b) any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a Member State, e.g. any business incorporated in the EU; and (c) any legal person, entity or body in respect of any business done in whole or in part within the EU, e.g. business done in the EU, irrespective of whether the individual is an EU national or the company is incorporated in the EU. The sanctions apply within the territory of the EU, including its airspace and on board any aircraft or vessel under the jurisdiction of a Member State. (b) non-eu entities which are more than 50 per cent owned by the Designated Banks (the Subsidiaries); and (c) companies acting on behalf, or at the direction, of the Designated Banks or their Subsidiaries. Any individual, or any company, falling within one or more of these categories must comply with the sanctions. 5. When do the restrictions come into force? The embargoes on exporting the targeted categories of goods and technologies to Russia and the prohibition on providing technical assistance, brokering services, financing or financial assistance in respect of such goods and technology, however, will apply to any natural or legal person, entity or body in Russia or for use in Russia. This is not restricted to Russian persons, entities or bodies. 3. What is the extent of the restrictions on Russian state-owned banks? It is prohibited to directly or indirectly sell, provide brokering services or assistance in the issuance of, or otherwise deal with transferable securities and money market instruments with a maturity exceeding 90 days, issued after 1 August 2014 by those entities referred to in question 2 above. The Regulation makes clear that other financial services such as deposit business, payment services and loans to or from these entities are not prohibited by the Regulation. The sanctions came into force on 1 August Do the sanctions apply to existing contracts? The sanctions generally only apply to the execution of obligations arising from contracts or agreements that are concluded on or after 1 August Existing contracts are not affected. Where authorisations for export of items are required under the Regulation, competent authorities may grant an authorisation where the export concerns the execution of an obligation arising from a contract concluded before 1 August 2014.

3 7. What constitutes energy-related equipment and technology and are there any exceptions to this restriction? The restrictions on exporting energy-related equipment and technology to Russia are limited to certain products, materials and technologies listed in Annex II to the Regulation. They include certain types of piping, casing, tools, drilling equipment, and more substantial machinery used in the oil and gas industry. 11. If you take steps to ensure you comply with the sanctions are you still at risk? The Regulation is drafted widely to seek to put as much pressure on the Russian economy as possible by restricting its access to funding and key equipment. However, liability will not arise if you did not know, and had no reasonable cause to suspect, that the actions in question would infringe the measures set out in the Regulation. Prior authorisation must be obtained for the supply of these items to Russia or for use in Russia or for the provision of technical assistance, brokering services, financing or financial assistance concerning them. Authorisation will be denied where the competent authority has reasonable grounds to determine that the products are destined for deep water oil exploration or production, Arctic oil exploration or production or shale oil projects in Russia. As announced by the EU, the Regulation does not prohibit exports for use in the gas industry. 8. What constitutes "technical assistance"? Technical assistance is extremely broadly defined and includes any technical support, instruction, advice, training, and transmission of knowledge or skills, including verbal assistance. 9. What are "dual-use goods"? The prohibition on exports of dual-use goods and technology for military use in Russia or to Russian military end-users relates to those goods listed in Annex 1 to EU Regulation 428/2009. They are goods which can have both civilian and military application. 10. What are military goods? EU individuals and entities should also ensure that they do not take any action that could be construed as an attempt to circumvent the sanctions. Such activity is also prohibited. Given the breadth of the prohibitions in the Regulation it is advisable that those persons and entities that must comply with the sanctions undertake extensive due diligence to ensure that their proposed activities are not in breach of the sanctions. 12. Are there any other restrictions? Additional restrictions have been enacted in Regulation 825/2014 relating to trade and investment in Crimea and Sevastopol. These include a ban on: (a) new investment in Crimea and Sevastopol, including the provision of brokering services and technical assistance in respect of such investment, in: i) infrastructure projects in transport, telecommunications and energy; and ii) exploitation of oil, gas and minerals. (b) the export of key equipment to transport, telecommunications, energy, oil, gas and minerals sectors in Crimea and Sevastopol; and The prohibition on providing technical assistance, financing or financial assistance in relation to military goods covers all items on the EU Common Military list. A link to the list can be found here. As noted above, a prohibition on the import and export of arms and related materiel to/from Russia is contained in the accompanying European Council Decision and will be implemented by Member States. (c) the provision of finance or insurance services relating to the above transactions. In addition, on 30 July 2014, the EU also amended Annex 1 to Regulation 269/2014 (enacted on 17 March 2014) to include a further eight individuals and three entities who are subject to asset freezes. Those individuals or entities are said to have provided support to or benefited from the actions of Russian decision-makers allegedly responsible for the destabilisation of eastern and the annexation of Crimea.

4 This brings the total number of persons and entities subject to EU restrictions to 117 individuals and 23 entities. A table setting out the designated individuals and entities is annexed to this briefing. 13. What are the consequences of breaching the sanctions? The penalties for breaching EU sanctions are imposed by the governments of each Member State. The Regulation requires only that penalties be effective, proportionate and dissuasive. As each Member State has discretion as to the penalties, they may differ across the EU. The penalties in the UK are imposed by statutory instruments enacted by the UK Government. On 1 August 2014, the UK enacted The (European Union Financial Sanctions) (No. 3) Regulations 2014, imposing the following penalties for breach of the provisions of the Regulation relating to financial transactions with Russian state-owned banks: a) for an individual, imprisonment for a term not exceeding two years or a fine, or both; and b) for a company, a fine and directors or officers of the company who consented to, or connived in, the contravention may also be imprisoned or fined. Contacts Ronnie King Partner, London T: +44 (0) E: ronnie.king@ashurst.com Sergei Ostrovsky Partner, London T: +44 (0) E: sergei.ostrovsky@ashurst.com Rob Moulton Partner, London T: +44 (0) E: rob.moulton@ashurst.com Michael Miran Counsel, New York T: E: michael.miran@ashurst.com Additional Contacts Gareth Hughes Partner, Hong Kong T: E: gareth.hughes@ashurst.com Ben Giaretta Partner, Singapore T: E: ben.giaretta@ashurst.com Chris Bailey Partner, Tokyo T: E: chris.bailey@ashurst.com Mark Elvy Partner, Sydney T: E: mark.elvy@ashurst.com Eric Bouffard Avocat à la Cour, Paris T: E: eric.bouffard@ashurst.com Jon Ericson Managing Partner, Stockholm T: E: jon.ericson@ashurst.com Tom Cummins Senior Associate, London T: +44 (0) E: tom.cummins@ashurst.com Robert Meade Associate, London T: +44 (0) E: robert.meade@ashurst.com Maximilian Boemke Rechtsanwalt, Counsel, Frankfurt T: E: maximilian.boemke@ashurst.com This publication is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Readers should take legal advice before applying the information contained in this publication to specific issues or transactions. For more information please contact us at Broadwalk House, 5 Appold Street, London EC2A 2HA T: +44 (0) F: +44 (0) Ashurst LLP is a limited liability partnership registered in England and Wales under number OC and is part of the Ashurst Group. It is a law firm authorised and regulated by the Solicitors Regulation Authority of England and Wales under number The term "partner" is used to refer to a member of Ashurst LLP or to an employee or consultant with equivalent standing and qualifications or to an individual with equivalent status in one of Ashurst LLP's affiliates. Further details about Ashurst can be found at Ashurst LLP 2014 Ref: August 2014

5 EU SANCTIONS ON UKRAINE: CONSOLIDATED LIST OF TARGETS 1 AUGUST INDIVIDUALS Last Name First Name Second Name DOB Position Group Type Regime Listed On 1. ABISOV Sergey 27/11/1967 Minister of Interior of the Republic of Crimea 2. AKSYONOV Sergey Valeryevich 26/11/1972 Prime Minister of Crimea 3. ARBUZOV Serhiy 24/03/1976 Former Prime Minister of the 15/04/ ANTYUFEYEV (a.k.a Vladimir SHEVTSOV, Vladimir Iurievici ANTIUFEEV, Vladimir Gheorghievici ALEXANDROV, Vadim Gheorghievici SHEVTSOV) Vladimir 19/02/1951 First Vice-Prime Minister 5. AZAROV Mykola Yanovych 17/12/1947 Former Prime Minister of until January 2014

6 6. AZAROV Oleksii Mykolayovych 13/07/1971 Son of former Prime Minister Azarov 7. BASHIROV Marat So called Prime Minister of the Council of Ministers of the People's Republic of Luhansk 12/07/ BELAVENTSEV Oleg Yevgenyvich 15/09/ BEREZIN Fedor 07/02/1960 The so-called 'Deputy Defence Minister' of the so-called Donetsk People's Republic. 10. BEREZOVSKIY Deniz Valentinovich 15/07/1974 Commander of the Ukrainian Navy (since 1 March 2014) 11. BESEDA Sergei Orestovoch 00/00/1954 Commander of the Fifth Service of the FSB, Federal Security Service of the Russian Federation BEZLER (A.K.A BEZLER, Igor Nikolaevich) Igor Mykolaiovych 30/12/1965 Militia leader. 13. BOHATYRIOVA Raisa Vasylivna 06/01/1953 Former Minister of Health 14. BOLOTOV Valeriy Dmitrievich 13/02/1970 One of the leaders of the separatist group 'Army of the South-East'. 15. BORODAI Aleksandr Yurevich 25/07/1972 So called Prime Minister of People's 12/07/2014

7 Republic of Donetsk. 16. BORTNIKOV Aleksandr Vasilievich 15/11/1951 Director of the Federal Security Service (FSB). Permanent member of the Security Council of the Russian Federation BUSHMIN Evgeni Viktorovich 04/10/1958 Deputy Speaker, Federation Council 18. CHALIY Aleksei Mikhailovich 13/06/1961 Mayor of Sevastopol (Since 23 February 2014) 19. DEGTYAREV Mikhail Vladimirovich 10/07/1981 Member of the State Duma. 20. DZHABAROV Vladimir Michailovich 29/09/1952 First Deputy Chairman, International Affairs Committee, Federation Council 21. FRADKOV Mikhail Efimovich 01/09/1950 Director of the Foreign Intelligence Service of the Russian Federation. Permanent member of the Security Council of the Russian Federation GALKIN Aleksandr Viktorovich 22/03/1958 Commander, Russia Southern Military District 23. GERASIMOV Valery Vasilevich 08/09/1955 General of the Army 24. GIRKIN (A.K.A STRELKOV, Igor Vsevolodovich 17/12/1970 Staff of Main Intelligence Directorate of the General Staff of the Armed Forces of the Russian Federation

8 Igor) (GRU). 25. GLAZYEV Sergey 01/01/1961 Advisor to the President of the Russian Federation 26. GROMOV Alexey Alexeyevich 31/05/1960 First Deputy Chief of Staff of the Presidential Administration 27. GRYZLOV Boris Vyacheslavovich 15/12/1950 Permanent member of the Security Council of the Russian Federation. 28. GUBAREV Pavel 10/02/1983 One of the self-described leaders of the so-called People's Republic of Donetsk. 29. GUBAREVA Ekaterina 05/07/1983 Minister of Foreign Affairs. The socalled 'Minister of Foreign Affairs' of the so-called Donetsk People's Republic. Her bank account is used to finance illegal armed separatist groups. 30. IVAKIN Yurij So called Minister of Internal Affairs of the People's Republic of Luhansk 12/07/ IVANYUSHCHENKO Yuriy 21/02/1959 Party of Regions MP 15/04/ JAROSH Petr Grigorievich Acting Head of the Federal Migration Service office for Crimea. 33. KADYROV Ramzan Akhmadovitch 05/10/1976 President of the Republic of Chechnya

9 34. KAKIDZYANOV Igor One of the leaders of the armed forces of the self-proclaimed 'Donetsk People's Republic'. 35. KALININ Ihor Oleksandrovych 28/12/1959 Former Adviser to the President of 36. KALYUSSKY Alexandr Aleksandrovich So called de facto Deputy Prime Minister for Social Affairs of Donetsk People's Republic. 12/07/ KARYAKIN Aleksey 00/00/1979 So called Supreme Council Chair of the People's Republic of Luhansk 12/07/ KAUROV Valery Vladimirovich 02/04/1956 President. The self-described 'President' of the so-called 'Republic of Novorossiya'. 39. KHODAKOVSKY Alexander So called Minister of Security of People's Republic of Donetsk 12/07/ KHRYAKOV Alexander So called Information and Mass Communications Minister of Donetsk People's Republic. 12/07/ KISELYOV Dmitry Konstantinovich 26/04/1954 Head of the Russian Federal State News Agency 'Rossiya Segodnya'. 42. KLISHAS Andrei Aleksandrovich 09/11/1972 Chairman, Committee on Constitutional Law, Federation Council 43. KLIUIEV Andrii Petrovych 12/08/1964 Former Head of Administration of

10 President of 44. KLIUIEV Serhii Petrovych 19/08/1969 Businessman. Brother of Mr. Andrii Kliuiev 45. KLYMENKO Oleksandr 16/11/1980 Former Minister of Revenues and Charges 15/04/ KONSTANTINOV Vladimir Andreevich 19/11/1956 Speaker, Verkhovna Rada of Crimea 47. KOVALCHUK Yuriy Valentinovich 25/07/1951 Chairman of Bank Rossiya; largest shareholder of Bank Rossiya; cofounder of Ozero Dacha, a cooperative society 48. KOVATIDI Olga Fedorovna 07/05/1962 Member of the Russian Federation Council from the annexed Autonomous Republic of Crimea 49. KOZAK Dmitry Nikolayevich 07/11/1958 Deputy Prime Minister 50. KOZITSYN Nikolay 20/06/1956 Commander of Cossack Forces 12/07/ KOZYURA Oleg Grigorievich 19/12/1962 Acting Head of the Federal Migration Service office for Sevastopol. 52. KULIKOV Valery Vladimirovich 01/09/1956 Rear Admiral, Deputy Commander of the Black Sea Fleet 53. KURCHENKO Serhiy Vitaliyovych 21/09/1985 Businessman

11 54. LITVINOV Boris Chairman of the 'Supreme Council' of the Donetsk People's Republic. 55. LUKASH Olena Leonidivna 12/11/1976 Former Minister of Justice 56. LYAGIN Roman 30/05/1980 Head of the 'Donetsk People's Republic' Central Electroral Commission. 57. MALOFEEV Konstantin Valerevich 03/07/ MALYKHIN Aleksandr Head of the 'Lugansk People's Republic' Central Electroral Commission. 59. MALYSHEV Mikhail Grigoryevich 10/10/1955 Chair of the Crimean Electoral Commission 60. MATVIYENKO Valentina Ivanova 07/04/1949 Speaker of the Federation Council 61. MEDVEDEV Valery Kirillovich 21/08/ MENYAILO Sergei Ivanovich 22/08/1960 Acting governor of Sevastopol 63. MIRONOV Sergei Mikhailovich 14/02/1953 Member, Council of the State Duma and Leader of Fair Russia faction in

12 the Duma of the Russian Federation 64. MIZULINA Elena Borisovna 09/12/1954 Deputy in the State Duma 65. MOZGOVY Oleksiy A leader of armed groups in Eastern. 12/07/ NARYSHKIN Sergei Evgenevich 27/10/1954 Speaker of the State Duma 67. NEVEROV Sergei Ivanovich 21/12/1961 Deputy Chairman of State Duma, United Russia 68. NIKITIN Vasyl So called Vice Prime Minister of the Council of Ministers of the People's Republic of Luhansk. Formerly so called Prime Minister of the People's Republic of Luhansk. 12/07/ NOSATOV Alexander Mihailovich 27/03/1963 Rear Admiral, Deputy Commander of the Black Sea Fleet 70. NURGALIEV Rashid Gumarovich 08/10/1956 Deputy Secretary of the Security Council of the Russian Federation. Permanent member of the Security Council of the Russian Federation OZEROV Viktor Alekseevich 05/01/1958 Chairman, Security and Defence Committee, Federation Council 72. PANTELEEV Oleg Evgenevich 21/07/1952 First Deputy Chairman, Committee on Parliamentary Issues, Federation

13 Council 73. PATRUSHEV Nikolai Platonovich 11/07/1951 Secretary of the Security Council of the Russian Federation. Permanent member of the Security Council of the Russian Federation PLIGIN Vladimir Nikolaevich 19/05/1960 Chair of the Duma Constitutional Law Committee. 75. PLOTNITSKY Igor So called Defence Minister of the People's Republic of Luhansk 12/07/ POKLONSKAYA Natalia Vladimirovna 18/03/1980 Prosecutor of Crimea. 77. PONOMARIOV (A.K.A PONOMARIOV, Vyacheslav Vladimirovich) Viacheslav 02/05/1965 Self-declared Mayor of Sloviansk 78. PORTNOV Andriy Volodymyrovych 27/10/1973 Former Adviser to the President of 79. PROKOPIV German Active leader of the 'Lugansk Guard'. 80. PSHONKA Artem Viktorovych 19/03/1976 Son of former Prosecutor General, Deputy Head of the faction of Party of Regions in the Verkhovna Rada of.

14 81. PSHONKA Viktor Pavlovych 06/02/1954 Former Prosecutor General of 82. PURGIN Andriy Yevgenevich 26/01/1972 Head of the 'Donetsk Republic'. 83. PUSHYLIN Denys One of the leaders of the Donetsk Peoples Republic. 84. RATUSHNIAK Viktor Ivanovych 16/10/1959 Former Deputy Minister of Internal Affairs 85. ROGOZIN Dmitry Olegovich 21/12/1963 Deputy Prime Minister of the Russian Federation 86. ROTENBERG Arkady Romanovich 15/12/1951 Major shareholder of Giprotransmost. 87. RYZHKOV Nikolai Ivanovich 28/09/1929 Member, Committee for Federal Issues, Regional Politics and the North, Federation Council 88. SAVELYEV Oleg Genrikhovich 27/10/1965 Minister for Crimean Affairs 89. SERGUN Igor Dmitrievich 28/03/1957 Director of GRU (Main Intelligence Directorate), Deputy Chief of the General Staff of the Armed Forces of the Russian Federation 90. SHAMALOV Nikolay Terentievich 24/01/1950 Co-founder of Ozero Dacha, a cooperative society; second largest shareholder of Bank Rossiya.

15 91. SHAMANOV Vladimir 15/02/1954 Commander of Russian Airborne Troops. 92. SHEVCHENKO Igor Sergeivich Acting Prosecutor of Sevastopol. 93. SHVETSOVA Ludmila Ivanovna 24/09/1949 Deputy Chairman of State Duma, United Russia 94. SIDOROV Anatoliy Alekseevich 02/07/1958 Commander, Russia s Western Military District 95. SLUTSKI Leonid Eduardovich 04/01/1968 Chairman, CIS Committee, State Duma of the Russian Federation and Member of LDPR 96. STAVYTSKYI Edward 04/10/1972 Former Minister of Fuel and Energy of. 15/04/ SURKOV Vladislav Yurievich 21/09/1964 Aide to the President of the Russian Federation 98. TABACHNYK Dmytro Volodymyrovych 28/11/1963 Former Minister of Education and Science 99. TCHIGRINA Oksana Spokesperson of the government of the Lugansk People's Republic TEMIRGALIEV Rustam Ilmirovich 15/08/1976 Deputy Chairman, Council of Ministers of Crimea 101. TKACHYOV Alexander Nikolayevich 23/12/1960 Governor of the Krasnodar Krai.

16 102. TOTOONOV Aleksandr Borisovich 03/03/1957 Member, Committee on Culture, Science and Information, Federation Council 103. TSARIOV Oleg Anatolevich 02/06/1970 Member of the Rada TSEKOV Sergey Pavlovych 28/03/1953 Vice-Speaker of the Verkhovna Rada 105. TSYPLAKOV Sergey Gennadevich 01/05/1983 One of the leaders of the People's Militia of Dombas TURCHENYUK Igor Nikolaevich 05/12/1959 Commander of Russian Forces in Crimea 107. VITKO Aleksandr Viktorovich 13/09/1961 Vice Admiral, Commander of the Russian Black Sea Fleet 108. VOLODIN Vyacheslav Viktorovich 04/02/1964 First Deputy Chief of Staff of the Presidential Administration of Russia YAKYMENKO Oleksandr Hryhorovych 22/12/1964 Former Head of Security Service of 110. YANUKOVYCH Oleksandr Viktorovych 10/07/1973 Son of former President. Businessman 111. YANUKOVYCH Viktor Fedorovych 09/07/1950 Former President of 112. YANUKOVYCH Viktor Viktorovych 16/07/1981 Member of the Verkhovna Rada of and Son of former President.

17 113. ZAKHARCHENKO Vitalii Yuriyovych 20/01/1963 Former Minister of Internal Affairs 114. ZDRILIUK Serhii Anatoliyovych 23/06/1972 Senior aide to Igor Strelkov/Girkin ZHELEZNYAK Sergei Vladimirovich 30/07/1970 Deputy Speaker of the State Duma of the Russian Federation 116. ZHEREBTSOV Yuriy Gennadyevich 19/11/1965 Counsellor of the Speaker of the Verkhovna Rada of Crimea 117. ZIMA Pyotr Anatolyevych 29/03/1965 Head of the Crimean Security Service (SBU) (Since 3 March 2014) 2. ENTITIES 1. ARMY OF THE SOUTHEAST Illegal armed separatist group. Associated with Mr. Valeriy BOLOTOV, listed as one of the leaders of the group. Also associated with Mr. Vasyl NIKITIN, responsible for the separatist governmental activities of the so called government of the People' s Republic of Luhansk 2. AZOV DISTILLERY PLANT Azovsky Likerovodochny Zavod 3. CHORNOMORNAFTOGAZ a.k.a: PJSC Chernomorneftegaz

18 4. DOBROLET a.k.a. Dobrolyot A subsidiary of a Russian state-owned airline. Its airline code is QD. Website: 5. DONBASS PEOPLE'S MILITIA Illegal armed separist group. 6. DONETSK PEOPLE'S REPUBLIC a.k.a: Donetskaya Narodnaya Respublika The so called Donetsk People's Republic was declared on 7 April On 24 May 2014, the so called People's Republics of Donetsk and Lugansk signed an agreement on the creation of the so called Federal State of Novorossiya. Official information including the Constitution of Donetsk People's Republic and the composition of the Supreme Council 7. FACTORY OF SPARKLING WINE NOVY SVET a.k.a: Zavod Shampanskykh Vin Novy Svet 8. FEDERAL STATE OF NOVOROSSIYA a.k.a: Federativnoye Gosudarstvo Novorossiya On 24 May 2014, the so called People's Republics of Donetsk and Lugansk signed an agreement on the creation of the unrecognized so called Federal State of Novorossiya. Official press releases 9. FEODOSIA a.k.a: Feodossyskoje Predprijatije Po Obespetscheniju Nefteproduktami Company providing transhipment services for crude oil and oil products

19 10. JOINT-STOCK COMPANY CONCERN ALMAZ- ANTEY a.k.a: (1) Almaz-Antey Corp. (2) Almaz-Antey Defense Corporation (3) Almaz-Antey JSC A Russian state-owned joint stock company. Website: INTERNATIONAL UNION OF PUBLIC ASSOCIATIONS GREAT DON ARMY The Great Don Army established the Cossack National Guard, responsible for the fighting against the Ukrainian Government forces in Eastern. Associated with Nikolay KOZITSYN, Commander of Cossack forces. Official web site: KERCH COMMERCIAL SEA PORT a.k.a: Kerchenski morskoy torgovy port 13. KERCH FERRY a.k.a: Kerchenskaya paromnaya pereprava 14. LUGANSK GUARD Self-defence militia of Lugansk. Associated with active leader Mr. German PROPOKIV 15. LUGANSK PEOPLE'S REPUBLIC The so called Lugansk People's Republic was established on 27 April On 22 May 2014, the so called People's Republics of Donetsk and Lugansk created the so called Federal State of Novorossiya. Official Website

20 a.k.a: Luganskaya Narodnaya Respublika Phone number MAGARACH OF THE NATIONAL INSTITUTE OF WINE a.k.a: (1) Agrofirma Magarach (2) Nacionalnogo Instituta Vinograda i Vina Magarach 17. NATIONAL ASSOCIATION PRODUCERS MASSANDRA OF a.k.a: Nacionalnoye Proizvodstvenno Agrarnoye Obyedinenye Massandra 18. RESORT NIZHNYAYA OREANDA 19. RUSSIAN NATIONAL COMMERCIAL BANK License of the Central Bank of Russia No SEVASTOPOL COMMERCIAL SEAPORT a.k.a: Sevastopolski

21 morskoy torgovy port 21. SOBOL a.k.a: Soboli Radical paramilitary organisation. Official website: UNIVERSAL-AVIA 23. VOSTOK BATTALION Illegal armed separatist group 3. RUSSIAN STATE-OWNED BANKS TARGETED BY PHASE THREE SANCTIONS (REGULATION 833/2014) 1. GAZPROMBANK Bank (Sovereignty phase three) 2. ROSSELKHOZBANK Bank (Sovereignty phase three) 3. SBERBANK Bank (Sovereignty phase three) 4. VNESHECHONOMBANK (VEB) Bank (Sovereignty phase three) 31/07/ VTB BANK Bank (Sovereignty phase three)