Please find below a summary of recent development regarding U.S. sanctions against Russia and a summary of the U.S. sanctions to date.

U.S. Sanctions
On September 12, the United States, in coordination with the EU, imposed additional sanctions against Russia in connection with events in Ukraine. Specifically,

1. the Office of Foreign Assets Control, U.S. Department of the Treasury (“OFAC”): (i) placed additional Russian persons on OFAC’s Specially Designated Nationals and Blocked Persons (“SDN”) list; (ii) placed additional Russian persons on OFAC’s Sectoral Sanctions Identifications List (“SSIL”); (iii) amended the bar on activities by U.S. persons relating to debt of SSIL-listed persons from the Russian financial services sector to cover new debt of more than 30 days maturity (previously the bar related to debt of 90 days or longer); (iv) imposed a bar on activities by U.S. persons relating to new debt of more than 30 days maturity of SSIL-listed persons from the Russian defense and related materiel sector; and (v) imposed a bar on activities by U.S. persons in support of  deepwater, Arctic offshore, or shale exploration or production projects that have the potential to produce oil in Russia and that involve any person designated on the SSIL in connection with the bar; and
2. the Bureau of Industry and Security, U.S. Department of Commerce (“BIS”): (i) added five entities from the Russian defense or related material sector to the BIS Entity List; (ii) added five entities from the Russian energy sector to the BIS Entity List, which are now subject to an export licensing requirement for certain energy projects; and (iii) imposed an export licensing requirement on certain Commerce Control List items known to be destined to Russia for a military end use or user (expanding the current licensing requirement for such exports to China to also cover Russia).

1. New OFAC Measures.
New Listings. OFAC placed additional Russian persons on OFAC’s SDN list and SSIL, including, in the case of the SSIL, designations in the Russian defense and related material and energy sectors in connection with Directives 3 and 4, described below. Notably, Sberbank, Russia’s largest bank, which previously had been spared inclusion, was added to the SSIL under Directive 1. The changes to these OFAC lists are detailed in Appendix A.

New Directive 3. On September 12, OFAC issued Directive 3 under its Ukraine sanctions, which prohibits U.S. persons from engaging in activities relating to new debt of longer than 30 days maturity of persons from the Russian defense and related materiel sector designated on the SSIL under Directive 3. Specifically, Directive 3 prohibits “all transactions in, provision of financing for, and other dealings in new debt of longer than 30 days maturity of persons determined to be subject to [Directive 3], their property, or their interests in property.”

In addition, OFAC also amended Directive 1, which relates to SSIL designations in the Russian financial sector, reducing the term of debt covered by that Directive from longer than 90 days to longer than 30 days. The term of debt covered by Directive 2, which relates to SSIL designations in the energy sector, remains unchanged and continues to cover new debt of longer than 90 days maturity.

New Directive 4. On September 12, OFAC also issued Directive 4, which introduces a new prohibition on activities by U.S. persons relating to certain energy projects in Russia. Directive 4 prohibits “the provision, exportation, or reexportation, directly or indirectly, of goods, services (except for financial services), or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that have the potential to produce oil in the Russian Federation, or in maritime area claimed by the Russian Federation,” involving any person designated on the SSIL under Directive 4. According to OFAC guidance, “the prohibition on the exportation of services includes, for example, drilling services, geophysical services, geological services, logistical services, management services, modeling capabilities, and mapping technologies,” but “[t]he prohibition does not apply to the provision of financial services” (emphasis in the original). On September 12, 2014, OFAC also issued General License 2, authorizing “all activities prohibited by Directive 4... that are ordinarily incident and necessary to the wind down of operations, contracts, or other agreements involving persons determined to be subject to Directive 4... and that were in effect prior to September 12, 2014” through 12:01 a.m. eastern daylight time, September 26, 2014.

2. New BIS Measures.
Entity List. BIS added certain persons from the Russian defense or related material and energy sectors to the BIS Entity List. This means that exports to such persons, as described in the terms of the listing, of items that are subject to the EAR will require a license, including exports of such items by non-U.S. persons who would not otherwise be subject to OFAC’s Directive 4. In the case of the energy sector companies listed, the licensing requirement applies “when the exporter, reexporter or transferor knows that the item will be used directly or indirectly in exploration for, or production of, oil or gas in Russian deepwater (greater than 500 feet) or Arctic offshore locations or shale formations in Russia.” Further, license applications for such projects that have the potential to produce oil will be reviewed with a presumption of denial:  

Persons operating in the Russian defense or related material sector added to BIS Entity List:

1. Almaz-Antey Air Defense Concern Main System Design Bureau, JSC;

2. Tikhomirov Scientific Research Institute of Instrument Design, JSC

3. Kalinin Machine Plant, JSC;

4. Mytishchinski Mashinostroitelny Zavod, OAO; and

5. Dolgoprudny Research Production Enterprise, OAO.

Persons operating in the Russian energy sector added to BIS Entity List:

1. Gazprom, OAO;
2. Gazprom Neft;
3. Lukoil, OAO;
4. Rosneft; and
5. Surgutneftegas.

New Licensing Requirement for Military End Uses and Users.  BIS previously established an export licensing requirement under Section 744.21 of the Export Administration Regulations (“EAR”) for certain items on the Commerce Control List when it is known the item is destined for a military end use or end user in China (which otherwise do not require a license for export to China). BIS has amended Section 744.21 to extend the licensing requirement for such items when it is known they are destined for a military end user or end use in Russia (which also otherwise do not require a license for export to Russia). The items that are subject to these license requirements are those listed in Supplement No. 2 to Part 744 of the EAR.

Overview of U.S. Sanctions Relating to Ukraine to Date

OFAC Sanctions

• Certain Russian and Ukrainian persons have been added to the OFAC SDN list and, as such, the property or interests in property of the listed persons that are in the U.S. or in the possession or control of a U.S. person (defined as an individual who is a citizen or resident of the U.S. or an entity organized or located in the U.S. and their non-U.S. branches) are blocked and no transactions by U.S. persons or from the U.S. with such SDNs are permitted;
• Certain Russian financial services, defense and related materiel, and energy sector entities have been placed on the newly established SSIL. U.S. persons are barred from involvement in activities relating to the issuance of new equity or new long term debt (from July 16 to September 12, with a term of 90 days or longer, and, as of September 12, 2014, with a term of 30 days or longer) for the financial sector entities (listed on the SSIL under OFAC Directive 1), new long term debt (90 days or longer) for the energy sector entities (listed on the SSIL under OFAC Directive 2), and new debt of longer than 30 days for the defense and related material sector entities (listed on the SSIL under OFAC Directive 3). Please note that long term payment terms in connection with the supply of goods or services can be considered a long term debt and a failure by a listed person to pay in less than the period prescribed as long term debt can give rise to an OFAC reporting requirement; and
• U.S. persons may not engage in any activities relating to exploration or production for deepwater, Arctic offshore, or shale projects that have the potential to produce oil in Russia and that involve any person in the energy sector designated on the SSIL in connection with the bar (under Directive 4).

BIS Restrictions

• Certain Russian persons have been placed on the Entity List under the EAR, which means any item described in the listing (usually any item subject to the EAR) requires a license to be exported or otherwise transferred to such persons. In the case of certain persons listed from the Russian energy sector, the licensing requirement applies to items that “will be used directly or indirectly in exploration for, or production of, oil or gas in Russian deepwater (greater than 500 feet) or Arctic offshore locations or shale formations in Russia;”
• Items classified under Export Control Classification Numbers (“ECCNs”) designated under the new EAR Russian Industry Sector Sanctions (see Section 746.5 of the EAR) or covered by a Schedule B Number listed on the Russian Industry Sector Sanctions List (in Supplement 2 to Part 746 of the EAR) require a license under the EAR if the exporter or reexporter knows or is informed the item will be used directly or indirectly in designated Russian energy sector applications (including for exploration or production from deepwater (greater than 500 feet), Arctic offshore, or shale projects in Russia that have the potential to produce oil or gas) or is unable to determine whether the item will be used in such projects in Russia. Please note there have been some modifications to the ECCN descriptions and the addition of a new ECCN for purposes of the Russian Industry Sector Sanctions List and, accordingly, the ECCN for any items sought to be supplied should be reevaluated under the post Sanctions ECCN descriptions. Also note that BIS has implemented a licensing policy of presumptive denial for all items subject to the EAR requiring a license for export to Russia in connection with Russian oil projects, including items not within the above-described ECCNs or Schedule B Numbers.  Since gas projects were not included in the policy of presumptive denial, it is assumed that license applications for gas projects will be reviewed on a case-by-case basis;
• BIS also announced a policy under the EAR that it will deny licenses to export or reexport any high technology item subject to the EAR to Russia or occupied Crimea that could contribute to Russia’s military capabilities; and
• The licensing requirement under the EAR for certain Commerce Control List items when exported or transferred with knowledge the item is intended for a military end use or end user in China has been extended to such exports to Russia.

U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) Restrictions

• In connection with BIS, the DDTC implemented a tightened policy to deny pending export license applications for any high technology items that could contribute to Russia’s military capabilities. DDTC is revoking any existing export licenses that meet these conditions and all other pending applications and existing licenses are receiving a case-by-case evaluation to determine their contribution to Russia’s military capabilities. 

Should you have any questions regarding the latest or historical sanctions, please do not hesitate to contact the authors.

APPENDIX A

AK TRANSNEFT OAO (a.k.a. AKTSIONERNAYA KOMPANIYA PO TRANSPORTUNEFTI TRANSNEFT OAO; a.k.a. OAO AK TRANSNEFT; a.k.a. OIL TRANSPORTING JOINT-STOCK COMPANY TRANSNEFT; a.k.a. TRANSNEFT; a.k.a. TRANSNEFT OJSC; a.k.a. TRANSNEFT, JSC), 57 B. Polyanka ul., Moscow 119180, Russia; 57 Bolshaya. Polyanka, Moscow 119180, Russia; website www.transneft.ru; e-mail address transneft@ak.transneft.ru; Executive Order 13662 Directive Determination - Subject to Directive 2; Registration ID 1027700049486; Tax ID No. 7706061801; Government Gazette Number 00044463; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].

LUKOIL OAO (a.k.a. LUKOIL; a.k.a. LUKOIL OIL COMPANY; a.k.a. NEFTYANAYA KOMPANIYA LUKOIL OOO; a.k.a. NK LUKOIL OAO), 11 Sretenski boulevard, Moscow 101000, Russia; website www.lukoil.ru; e-mail address info@lukoil.ru; Executive Order 13662 Directive Determination - Subject to Directive 4; Registration ID 1027700035769; Tax ID No. 7708004767; Government Gazette Number 00044434; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].

OJSC GAZPROM NEFT (a.k.a. GAZPROM NEFT OAO; a.k.a. JSC GAZPROM NEFT; a.k.a. OPEN JOINT-STOCK COMPANY GAZPROM NEFT; f.k.a. SIBIRSKAYA NEFTYANAYA KOMPANIYA OAO), Let. A. Galernaya, 5, ul, St. Petersburg 190000, Russia; Ul. Pochtamtskaya, 3-5, St. Petersburg 190000, Russia; 3-5 Pochtamtskaya St., St. Petersburg 190000, Russia; 125 A. Profsoyuznaya Street, Moscow 117647, Russia; website http://www.gazprom-neft.com/; e-mail address info@gazprom-neft.ru; alt. e-mail address pr@gazprom-neft.ru; alt. e-mail address shareholders@gazprom-neft.ru; alt. e-mail address ir@gazprom-neft.ru; Executive Order 13662 Directive Determination - Subject to Directive 2; alt. Executive Order 13662 Directive Determination - Subject to Directive 4; Registration ID 1025501701686; Tax ID No. 5504036333; Government Gazette Number 42045241; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].
 
OPEN JOINT STOCK COMPANY GAZPROM (a.k.a. GAZPROM OAO; a.k.a. OAO GAZPROM), 16 Nametkina St., Moscow, Russia GSP-7, 117997, Russia; 16 Nametkina ul., Moscow 117991, Russia; website www.gazprom.ru; e-mail address gazprom@gazprom.ru; Executive Order 13662 Directive Determination - Subject to Directive 4; Registration ID 1027700070518 (Russia); Tax ID No. 7736050003 (Russia); Government Gazette Number 00040778 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].
 
ROSTEC (a.k.a. ROSTEC STATE CORPORATION; a.k.a. RUSSIAN TECHNOLOGIES; a.k.a. RUSSIAN TECHNOLOGIES STATE CORPORATION FOR ASSISTANCE TO DEVELOPMENT, PRODUCTION AND EXPORT OF ADVANCED TECHNOLOGY INDUSTRIAL PRODUCT; a.k.a. STATE CORPORATION FOR ASSISTANCE TO DEVELOPMENT, PRODUCTION AND EXPORT OF ADVANCED TECHNOLOGY INDUSTRIAL PRODUCT ROSTEKHNOLOGII; a.k.a. STATE CORPORATION ROSTECHNOLOGII; a.k.a. STATE CORPORATION ROSTEKHNOLOGII), 24 Usacheva ul., Moscow 119048, Russia; 21 Gogolevsky Blvd., Moscow 119991, Russia; website www.rostec.ru; e-mail address info@rostec.ru; Executive Order 13662 Directive Determination - Subject to Directive 3; Registration ID 1077799030847 (Russia); Tax ID No. 7704274402 (Russia); Government Gazette Number 94137372 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].
 
SBERBANK OF RUSSIA (f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO SBERBANK ROSSII; a.k.a. SBERBANK ROSSII; f.k.a. SBERBANK ROSSII OAO), 19 ul. Vavilova, Moscow 117997, Russia; SWIFT/BIC SABRRUMM; website www.sberbank.ru; e-mail address sbrf@sbrf.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].
 
SURGUTNEFTEGAS (a.k.a. OPEN JOINT STOCK COMPANY SURGUTNEFTEGAS; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO SURGUTNEFTEGAZ; a.k.a. SURGUTNEFTEGAS OAO; a.k.a. SURGUTNEFTEGAS OJSC; a.k.a. SURGUTNEFTEGAZ OAO), ul. Grigoriya Kukuyevitskogo, 1, bld. 1, Khanty-Mansiysky Autonomous Okrug - Yugra, the city of Surgut, Tyumenskaya Oblast 628415, Russia; korp. 1 1 Grigoriya Kukuevitskogo ul., Surgut, Tyumenskaya oblast 628404, Russia; Street Kukuevitskogo 1, Surgut, Tyumen Region 628415, Russia; website www.surgutneftegas.ru; e-mail address secretary@surgutneftegas.ru; Executive Order 13662 Directive Determination - Subject to Directive 4; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662].

The following changes have been made to OFAC’s Sectoral Sanctions Identifications List:

BANK OF MOSCOW (f.k.a. AKTSIONERNY KOMMERCHESKI BANK BANK MOSKVY, OTKRYTOE AKTSIONERNOE OBSCHCHESTVO; a.k.a. JOINT STOCK COMMERCIAL BANK - BANK OF MOSCOW, OPEN JOINT STOCK COMPANY), 8/15 Korp. 3 ul. Rozhdestvenka, Moscow 107996, Russia; Bld 3 8/15, Rozhdestvenka St., Moscow 107996, Russia; SWIFT/BIC MOSW RU MM; website www.bm.ru; e-mail address holmogorov_ss@mmbank.ru; alt. e-mail address info@mmbank.ru; BIK (RU) 044525219; Registration ID 1027700159497; Government Gazette Number 29292940; The following transactions by U.S. persons or within the United States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- BANK OF MOSCOW (f.k.a. AKTSIONERNY KOMMERCHESKI BANK BANK MOSKVY, OTKRYTOE AKTSIONERNOE OBSCHCHESTVO; a.k.a. JOINT STOCK COMMERCIAL BANK - BANK OF MOSCOW, OPEN JOINT STOCK COMPANY)|, 8/15 Korp. 3 ul. Rozhdestvenka, Moscow 107996, Russia; Bld 3 8/15, Rozhdestvenka St., Moscow 107996, Russia; SWIFT/BIC MOSW RU MM; website www.bm.ru; e-mail address holmogorov_ss@mmbank.ru; alt. e-mail address info@mmbank.ru; BIK (RU) 044525219; Executive Order 13662 Directive Determination - Subject to Directive 1; Registration ID 1027700159497; Government Gazette Number 29292940; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].

GAZPROMBANK OAO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a. GPB, OJSC), 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; website www.gazprombank.ru; e-mail address mailbox@gazprombank.ru; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684; The following transactions by U.S. persons or within the United States are hereby prohibited:  transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- GAZPROMBANK OAO (a.k.a. GAZPROMBANK GAS INDUSTRY OJSC; a.k.a. GAZPROMBANK OJSC; a.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; a.k.a. GAZPROMBANK OTKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. GPB, OAO; a.k.a. GPB, OJSC)|, 16, Building 1, Nametkina St., Moscow 117420, Russia; 63, Novocheremushkinskaya St., Moscow 117418, Russia; SWIFT/BIC GAZPRUMM; website www.gazprombank.ru; e-mail address mailbox@gazprombank.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Registration ID 1027700167110; Tax ID No. 7744001497; Government Gazette Number 09807684; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].

OAO NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST OAO; a.k.a. NOVATEK), 2, Udaltsova Street, Moscow 119415, Russia; 22 A, Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; e-mail address novatek@novatek.ru; Registration ID 1026303117642 (Russia); Government Gazette Number 33556474 (Russia); The following transactions by U.S. persons or within the United States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- OAO NOVATEK (a.k.a. FINANSOVO-INVESTITSIONNAYA KOMPANIYA NOVAFININVEST OAO; a.k.a. NOVATEK)|, 2, Udaltsova Street, Moscow 119415, Russia; 22 A, Pobedy Street, Tarko-Sale, Yamalo-Nenets Autonomous District 629580, Russia; 22a Pobedy ul., Tarko-Sale, Purovski raion, Tyumenskaya Oblast 629850, Russia; e-mail address novatek@novatek.ru; Executive Order 13662 Directive Determination - Subject to Directive 2; Registration ID 1026303117642 (Russia); Government Gazette Number 33556474 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].

OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY), 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; website www.rosneft.com; alt. website www.rosneft.ru; e-mail address postman@rosneft.ru; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia); The following transactions by U.S. persons or within the United States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- OPEN JOINT-STOCK COMPANY ROSNEFT OIL COMPANY (a.k.a. OAO ROSNEFT OIL COMPANY; a.k.a. OIL COMPANY ROSNEFT; a.k.a. OJSC ROSNEFT OIL COMPANY; a.k.a. ROSNEFT; a.k.a. ROSNEFT OIL COMPANY)|, 26/1 Sofiyskaya Embankment, Moscow 115035, Russia; website www.rosneft.com; alt. website www.rosneft.ru; e-mail address postman@rosneft.ru; Executive Order 13662 Directive Determination - Subject to Directive 2; alt. Executive Order 13662 Directive Determination - Subject to Directive 4; Registration ID 1027700043502 (Russia); Tax ID No. 7706107510 (Russia); Government Gazette Number 00044428 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].

RUSSIAN AGRICULTURAL BANK (f.k.a. OTKRYTOE AKTSIONERNOE ROSSISKI SELSKOKHOZYAISTVENNY BANK; a.k.a. ROSSELKHOZBANK; a.k.a. ROSSIYSKI SELSKOKHOZYAISTVENNY BANK OAO; a.k.a. RUSSIAN AGRICULTURAL BANK OAO), 3, Gagarinsky Pereulok, Moscow 119034, Russia; 3 Gagarinsky per., Moscow 119034, Russia; SWIFT/BIC RUAG RU MM; website http://www.rshb.ru; e-mail address office@rshb.ru; Registration ID 1027700342890; Government Gazette Number 52750822; The following transactions by U.S. persons or within the United States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- RUSSIAN AGRICULTURAL BANK (f.k.a. OTKRYTOE AKTSIONERNOE ROSSISKI SELSKOKHOZYAISTVENNY BANK; a.k.a. ROSSELKHOZBANK; a.k.a. ROSSIYSKI SELSKOKHOZYAISTVENNY BANK OAO; a.k.a. RUSSIAN AGRICULTURAL BANK OAO)|, 3, Gagarinsky Pereulok, Moscow 119034, Russia; 3 Gagarinsky per., Moscow 119034, Russia; SWIFT/BIC RUAG RU MM; website http://www.rshb.ru; e-mail address office@rshb.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Registration ID 1027700342890; Government Gazette Number 52750822; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].

VNESHECONOMBANK (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE CORPORATION; a.k.a. BANK RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. “VEB”), 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; website http://www.veb.ru; e-mail address info@veb.ru; BIK (RU) 044525060; The following transactions by U.S. persons or within the United States are hereby prohibited:  transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- VNESHECONOMBANK (a.k.a. BANK FOR DEVELOPMENT AND FOREIGN ECONOMIC AFFAIRS (VNESHECONOMBANK) STATE CORPORATION; a.k.a. BANK RAZVITIYA I VNESHNEEKONOMICHESKOI DEYATELNOSTI (VNESHEKONOMBANK) GOSUDARSTVENNAYA KORPORATSIYA; a.k.a. “VEB”)|, 9 Akademika Sakharova prospekt, Moscow 107996, Russia; SWIFT/BIC BFEA RU MM; website http://www.veb.ru; e-mail address info@veb.ru; BIK (RU) 044525060; Executive Order 13662 Directive Determination - Subject to Directive 1; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].

VTB BANK OAO (f.k.a. BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII, CLOSED JOINT-STOCK COMPANY; f.k.a. BANK VNESHNEY TORGOVLI RSFSR; f.k.a. BANK VNESHNEY TORGOVLI, JOINT-STOCK COMPANY; f.k.a. BANK VNESHNEY TORGOVLI, OPEN JOINT-STOCK COMPANY; a.k.a. BANK VTB OAO; a.k.a. BANK VTB, OPEN JOINT-STOCK COMPANY; a.k.a. JSC VTB BANK; f.k.a. VNESHTORGBANK; f.k.a. VNESHTORGBANK ROSSII, CLOSED JOINT-STOCK COMPANY; a.k.a. VTB BANK, OPEN JOINT-STOCK COMPANY), 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia; 37 Plyushchikha ul., Moscow 119121, Russia; 43, Vorontsovskaya str., Moscow 109044, Russia; SWIFT/BIC VTBRRUMM; website www.vtb.com; Registration ID 1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government Gazette Number 00032520 (Russia); License 1000 (Russia); The following transactions by U.S. persons or within the United States are hereby prohibited:  transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- VTB BANK OAO (f.k.a. BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII, CLOSED JOINT-STOCK COMPANY; f.k.a. BANK VNESHNEY TORGOVLI RSFSR; f.k.a. BANK VNESHNEY TORGOVLI, JOINT-STOCK COMPANY; f.k.a. BANK VNESHNEY TORGOVLI, OPEN JOINT-STOCK COMPANY; a.k.a. BANK VTB OAO; a.k.a. BANK VTB, OPEN JOINT-STOCK COMPANY; a.k.a. JSC VTB BANK; f.k.a. VNESHTORGBANK; f.k.a. VNESHTORGBANK ROSSII, CLOSED JOINT-STOCK COMPANY; a.k.a. VTB BANK, OPEN JOINT-STOCK COMPANY)|, 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia; 37 Plyushchikha ul., Moscow 119121, Russia; 43, Vorontsovskaya str., Moscow 109044, Russia; SWIFT/BIC VTBRRUMM; website www.vtb.com; Executive Order 13662 Directive Determination - Subject to Directive 1; Registration ID 1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government Gazette Number 00032520 (Russia); License 1000 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.| [UKRAINE-EO13662].

The following entities have been added to OFAC’s SDN List:

JOINT STOCK COMPANY ALMAZ-ANTEY AIR DEFENSE CONCERN MAIN SYSTEM DESIGN BUREAU NAMED BY ACADEMICIAN A.A. RASPLETIN (a.k.a. A.A. RASPLETIN MAIN SYSTEM DESIGN BUREAU; a.k.a. ALMAZ-ANTEY GSKB; a.k.a. ALMAZ-ANTEY GSKB IMENI ACADEMICIAN A.A. RASPLETIN; a.k.a. ALMAZ-ANTEY MSDB; a.k.a. ALMAZ-ANTEY PVO ‘AIR DEFENSE’ CONCERN LEAD SYSTEMS DESIGN BUREAU OAO ‘OPEN JOINT-STOCK COMPANY’ IMENI ACADEMICIAN A.A. RASPLETIN; a.k.a. GOLOVNOYE SISTEMNOYE KONSTRUKTORSKOYE BYURO OPEN JOINT-STOCK COMPANY OF ALMAZ-ANTEY PVO CONCERN IMENI ACADEMICIAN A.A. RASPLETIN; a.k.a. JSC ‘ALMAZ-ANTEY’ MSDB; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO NAUCHNO PROIZVODSTVENNOE OBEDINENIE ALMAZ IMENI AKADEMIKA A.A. RASPLETINA; a.k.a. “GSKB”), 16-80, Leningradsky Prospect, Moscow 125190, Russia; website http://www.raspletin.ru/; e-mail address info@raspletin.ru; alt. e-mail address almaz_zakupki@mail.ru [UKRAINE-EO13661].

JSC V. TIKHOMIROV SCIENTIFIC RESEARCH INSTITUTE OF INSTRUMENT DESIGN (a.k.a. JSC NIIP; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO NAUCHNO ISSLEDOVATELSKI INSTITUT PRIBOROSTROENIYA IMENI V.V. TIKHOMIROVA), 3 Ul. Gagarina, Zhukovski, Moskovskaya Obl 140180, Russia; Gagarin Str, 3, Zhukovsky 140180, Russia; website http://www.niip.ru; e-mail address niip@niip.ru; Registration ID 1025001627859; Government Gazette Number 13185231 (Russia) [UKRAINE-EO13661].

KALININ MACHINE PLANT JSC (a.k.a. KALININ MACHINE-BUILDING PLANT OPEN JOINT-STOCK COMPANY; a.k.a. KALININ MACHINERY PLANT-BRD; a.k.a. MASHINOSTROITEL’NYI ZAVOD IM. M.I. KALININA, G. YEKATERINBURG OAO; a.k.a. MZIK OAO; a.k.a. OPEN-END JOINT-STOCK COMPANY ‘KALININ MACHINERY PLANT. YEKATERINBURG’; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO MASHINOSTROITELNY ZAVOD IM.M.I.KALININA, G.EKATERINBURG), 18 prospekt Kosmonavtov, Ekaterinburg, Sverdlovskaya obl. 620017, Russia; e-mail address info@zik.ru [UKRAINE-EO13661].

MYTISHCHINSKI MASHINOSTROITELNY ZAVOD, OAO (a.k.a. JSC MYTISHCHINSKI MACHINE-BUILDING PLANT; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO ‘MYTISHCHINSKI MASHINOSTROITELNY ZAVOD’), 4 ul. Kolontsova Mytishchi, Mytishchinski Raion, Moskovskayaobl 141009, Russia; UL. Koloncova, d.4, Mytishi, Moscow region 141009, Russia; website www.mmzavod.ru; e-mail address mmzavod@mail.ru; Registration ID 1095029003860 (Russia); Government Gazette Number 61540868 (Russia) [UKRAINE-EO13661].

OAO ‘DOLGOPRUDNY RESEARCH PRODUCTION ENTERPRISE’ (a.k.a. DOLGOPRUDNENSKOYE NPP OAO; a.k.a. DOLGOPRUDNY; a.k.a. DOLGOPRUDNY RESEARCH PRODUCTION ENTERPRISE; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO DOIGOPRUDNENSKOE NAUCHNO PROIZVODSTVENNOE PREDPRIYATIE), 1 Pl. Sobina, Dolgoprudny, Moskovskaya obl. 141700, Russia; Proshchad Sobina 1, Dolgoprudny 141700, Russia; e-mail address dnpp@orc.ru; Registration ID 1025001202544; Tax ID No. 5008000322; Government Gazette Number 07504318 [UKRAINE-EO13661].