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Dear clients,

As of March 9, 2022 a new regulation regulating further anti-Russian sanctions and newly anti-Belarusian sanctions in connection with the ongoing Ukraine crisis, in which Belarus is also involved to a large extent, has been published in the Official Journal of the European Union.

The newly imposed sanctions against Belarus are governed by the Council Regulation (EU) 2022/398 of 9 March 2022 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, which is available here.

The newly imposed anti-Belarussian sanctions take the following form:

• It shall be prohibited as of 20 March 2022 to provide specialised financial messaging services, which are used to exchange financial data (SWIFT), to the legal persons, entities or bodies listed in Annex XV or to any legal person, entity or body established in Belarus whose proprietary rights are directly or indirectly owned for more than 50 % by an entity listed in Annex XV (Belagroprombank, Bank Dabrabyt, Development Bank of the Republic of Belarus);

• Transactions related to the management of reserves as well as of assets of the Central Bank of Belarus, including transactions with any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Belarus, are prohibited;

• It shall be prohibited to list and provide services as of 12 April 2022 on trading venues registered or recognised in the Union for the transferable securities of any legal person, entity or body established in Belarus and with over 50 % public ownership;

• It shall be prohibited to provide public financing or financial assistance for trade with, or investment in, Belarus;

• It shall be prohibited to accept any deposits from Belarusian nationals or natural persons residing in Belarus, or legal persons, entities or bodies established in Belarus, if the total value of deposits of the natural or legal person, entity or body per credit institution exceeds EUR 100 000;

• It shall be prohibited to sell euro denominated transferable securities issued after 12 April 2022 or units in collective investment undertakings providing exposure to such securities, to any Belarusian national or natural person residing in Belarus or any legal person, entity or body established in Belarus;

• It shall be prohibited to sell, supply, transfer or export euro denominated banknotes to Belarus or to any natural or legal person, entity or body in Belarus, including the government and the Central Bank of Belarus, or for use in Belarus, whereas the prohibition shall not apply to the sale, supply, transfer or export of euro denominated banknotes provided that such sale, supply, transfer or export is necessary for:

a)   the personal use of natural persons travelling to Belarus or members of their immediate families travelling with them; or

b)   the official purposes of diplomatic missions, consular posts or international organisations in Belarus enjoying immunities in accordance with international law.

Furthermore, the Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, available here, extended the already effective anti-Russian sanctions, in particular:

• The term "transferable securities" has been extended to include securities in the form of crypto-assets negotiable on the capital market;

• Prohibition in relation to the supply of maritime goods and technology, to any natural or legal person, entity or body in Russia, for use in Russia or for incorporation on board a Russian flagged vessel, in particular navigation and radio communication equipment;

Also, Council Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, available here, extended the sanctions list by an additional 160 persons which are subject to, in particular:

• asset freeze,

• travel ban to EU countries,

• restrictions of EU citizens and companies which are forbidden from making funds available.

These include, in particular, entrepreneurs operating in the metallurgical, agricultural, pharmaceutical, telecommunications and digital sectors and their family members, as well as 146 members of the Russian Federation Council who ratified the governmental decisions of the "Treaty on Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People's Republic" and the "Treaty on Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Luhansk People's Republic".

In case of any questions about the above, we of course remain available to you.