Litigation

1 RUSSIA The US and Western allies this quarter escalated sweeping sanctions and trade restrictions against Russia in response to its ongoing invasion of Ukraine. Full Blocking Sanctions Imposed on Additional Russian Financial Institutions This quarter, OFAC expanded sanctions on Russia's financial sector by adding major banks to its List of Specially- Designated Persons (SDN). On April 6, OFAC designated PJSC Sberbank of Russia, Russia's largest financial institution, as well as numerous of its subsidiaries, officers, and directors. It is believed that Sberbank holds about one-third of all bank assets in Russia and is the main creditor of the Russian economy. Also, on April 6, OFAC designated JSC Alfa-Bank, Russia's largest privately owned financial institution and fourth-largest bank. On May 8, OFAC designated JSC Moscow Industrial Bank (MIB) and ten of its subsidiaries. According to OFAC, MIB, a Russian state-owned bank, has engaged with a number of sanctioned entities, including by taking on the business of sanctioned entity Promsvyazbank and helping the designated PJSC Transkapitalbank to move US dollars. MIB has also allegedly facilitated transactions on behalf of Russia's intelligence services. New US Trade Restrictions and Investment Bans On April 6, President Biden issued Executive Order 14071 ("Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression"). The E.O., which builds on previous E.O.s 14066 and 14068, bans all "new investment" in the Russian Federation by US persons, wherever located. Notably, OFAC clarified in published guidance that the ban extends to the purchase of all new and pre- existing debt and equity securities issued by any entity in the Russian Federation—not just those specifically named in sanctions. Accordingly, US persons are prohibited from buying Russian securities, including corporate or government bonds or equities, on the primary or secondary markets. However, US persons may continue to sell such assets, or facilitate their sale, to non-US persons and may continue to hold them pending the removal of sanctions. US investors may also purchase shares in diversified funds having a less-than-predominant exposure to Russia-linked debt. E.O. 14071 also prohibits US persons from providing, directly or indirectly, any services as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, to entities or individuals in Russia. On

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