The World Reacts to the Crisis in Ukraine:

Sanctions and Export Controls Imposed by

the U.S., the EU, the UK and Other
Countries

March 10/11, 2022

Panelists:
Patrick Doris
Christopher Timura
Richard Roeder
Claire Yi
Moderator: David Wolber
Today’s Panel

David A. Wolber Patrick Doris Christopher T. Timura

Of Counsel, Hong Kong Partner, London Of Counsel, Washington, D.C.

Richard Roeder Claire Yi

Associate, Munich Associate, Washington, D.C.

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 Agenda

1. Introduction
2. Major U.S. Developments
3. Major EU Developments
4. Major UK Developments
5. Developments in Asia

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Introduction
Major U.S. Developments
 U.S. Sanctions
Key Developments – Financial Institutions

The United States has issued the Russian Harmful Foreign Activities Sanctions Regulations (31 C.F.R. 587), which implements
E.O. 14024 from 2021.
Targeting Russian Financial Institutions:
• Blocking sanctions apply to six major financial institutions, along with their subsidiaries (both those that are listed on the
SDN List and those that are owned 50% or more by blocked entities). Designated entities are on the SDN List.
• Directive 2: Restricts (1) opening and maintaining of correspondent and payable-through account for or (2) processing
transactions involving Sberbank, Russia’s largest bank. Sberbank and 25 designated subsidiaries are on the CAPTA List.
• Directive 3: Restricts dealing in new debt longer than 14 days and new equity of eight state-owned firms—Gazprom,
Gazprom Neft, Transneft, Rostelecom, RusHydro, Alrosa, Sovcomflot, and Russian Railways—and five banks. Designated
entities are on the non-SDN MBS List.
Certain Transactions Related to Existing
Name Type of Restriction General Wind-Down Energy Transactions Fifty Percent Rule
Debt and Equity or Derivative Contracts
PSB SDN Yes
VEB SDN Until March 24 Until May 25 Until June 24 Yes
VTB SDN Until March 26 Until May 25 Until June 24 Yes
Otkritie SDN Until March 26 Until May 25 Until June 24 Yes
Sovcombank SDN Until March 26 Until May 25 Until June 24 Yes
Novikom SDN Yes
Sberbank Directive 2 & 3 Until May 25 Until June 24 Yes
Gazprombank Directive 3 Yes
Alfa-Bank Directive 3 Yes
Russian Agricultural Bank Directive 3 Yes
Credit Bank of Moscow Directive 3 Yes

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 U.S. Sanctions
Key Developments – Others

Targeting Sovereign Wealth Entities:

• Blocking sanctions apply to Russian Direct Investment Fund.
• Directive 1A: Expands restrictions to dealing in the secondary market for bonds issued by the Central Bank, the National
Wealth Fund, or the Ministry of Finance.
• Directive 4: Restricts any transaction involving the Central Bank, the National Wealth Fund, or the Ministry of Finance.
Does not restrict transaction where the Directive 4 entity’s sole function is to operate a clearing and settlement system,
provided that: (i) there is no transfer of assets to or from any Directive 4 entity; and (ii) no Directive 4 entity is either a
counterparty or a beneficiary to the transaction. These entities are on the non-SDN MBS List.
Name Type of Restriction Certain Transactions Related to Existing Debt Energy Transactions Taxes and Fees
and Equity or Derivative Contracts
Russian Direct Investment Fund SDN
Central Bank Directive 1A & 4 Until May 25 Until June 24 Until June 24
National Wealth Fund Directive 1A & 4 Until May 25 Until June 24
Ministry of Finance Directive 1A & 4 Until May 25 Until June 24
Prohibition on import of Russian energy products and new investment into the Russian energy sector.
Comprehensive sanctions on the so-called Donetsk People’s Republic and Luhansk People’s Republic regions.
Blocking sanctions on:
• President Vladimir Putin, several high-level officials, and close Putin associates.
• Belarusian state-owned banks and eleven entities in the defense and mining sectors.
• Nord Stream 2 AG.
• Persons in connection with the Russian Government’s efforts to promulgate disinformation and influence perceptions.

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 U.S. Export Controls
Key Developments

The United States significantly expanded its controls on the exports of U.S. goods, software and technologies to or within
Russia:
New Commerce Control List (“CCL)” Controls: New license requirements for exports to Russia on all Export Control
Classification Numbers (“ECCN”) in Categories 3–9 of the CCL.
Expanded Military End User (“MEU”) and End Use Controls: Expands current restrictions on Russian ‘military end users’ and
‘military end uses’ to cover all items subject to the EAR, with limited exceptions.
Two New Foreign Direct Product (“FDP”) Rules:
• A general FDP rule establishing controls over foreign-produced items exported to Russia that are: (i) the direct product
of certain U.S.-origin software or technology subject to the EAR; or (ii) produced by plants or equipment which are
themselves the direct product of certain U.S.-origin software or technology subject to the EAR. This rule does not apply
to foreign made items that would be classified as EAR99.
• A more extensive FDP rule on exports to Russian MEUs of foreign-produced items that are: (i) the direct product of any
software or technology subject to the EAR that is on the CCL; or (ii) produced by plants or equipment which are
themselves the direct product of any U.S.-origin software or technology on the CCL. Covered entities are on the BIS
Entity List with a “footnote 3 designation.” This rule applies to EAR99 items, with limited exceptions.
• All “partner countries” are excluded from the scope of the new FDP rules.

Entity List additions: 47 transfers from the MEU List and over 90 new entries on the Entity List.
All Russia-related license applications with be treated under a policy of denial with limited exceptions.

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 U.S. Export Controls
Jurisdiction Scenarios

① Item-Based Controls

Because 3A001 is
3A001
controlled under
Categories 3 – 9 of the
CCL, a license is required.
② De Minimis Rule
Because 3A001 is
3A001
3A001
EAR99 controlled content and is
Non-U.S. >25% value of finished
product, a license is
Value $0.26 Value: $1.00
required.
Non-U.S. country

③ Foreign Direct Product Rule – Russia Because the 3A001 item is

a direct product of U.S.
5D001 3A001 software and technology, a
license is required for
Non-partner export to Russia.
country
④ Foreign Direct Product Rule – Russia MEU Because the EAR99 item is
a direct product of U.S.
EAR99 software and technology, a
5D001
license is required for
export to Russian military
Non-partner
end user (Entity List with
country footnote 3 designation).

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 U.S. Export Controls
Foreign Direct Product Rule

① Standard Foreign Direct Product Rule – Software ② Standard Foreign Direct Product Rule – Technology

5D001 3A001 3A001

5E001

Direct product of Direct product of

U.S.-origin U.S.-origin
software technology

③ Plants and Major Components

Non-partner
country

5D001

3A001

Design Engineering Manufacturing Testing

5E001
Produced with plants or major components that are themselves
the direct product of U.S.-origin software or technology

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 U.S. Export Controls
Partner Countries

List of Partner Countries as of March 10, 2022

Australia Japan
Austria Latvia
Belgium Lithuania
Bulgaria Luxembourg
Canada Malta
Croatia Netherlands
Cyprus New Zealand
Czech Republic Poland
Denmark Portugal
Estonia Romania
Finland Slovakia
France Slovenia
Germany South Korea
Greece Spain
Hungary Sweden
Ireland United Kingdom
Italy

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Major EU Developments
 EU Sanctions – Financial Sanctions

The European Union has amended its pre-existing Russia-related financial sanctions regime, including Council
Regulation (EU) No 269/2014 of 17 March 2014, by several rounds of additional listings.

Broadly comparable to U.S. blocking sanctions, EU financial sanctions include an asset freeze and the
prohibition on making available, directly or indirectly, funds or economic resources to or for the benefit of
those listed.

Listings are closely aligned with the U.S. and the UK, yet timing of the listings varies.

In total, more than 862 people and 53 entities are, as of today, subject to EU Russia financial sanctions and a
corresponding travel ban because “(…) their actions have undermined Ukraine's territorial integrity, sovereignty
and independence.”

Listings include President Vladimir Putin, Minister for Foreign Affairs Sergey Lavrov, members of the Duma
that voted in favour of recognition by Russia of the non-government controlled areas of the Donetsk and
Luhansk oblasts in Ukraine as independent entities and further individuals and entities deemed to have
facilitated Russia’s past and recent actions undermining Ukraine’s territorial sovereignty, including several
individuals referred to as “Oligarchs.”

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 EU Sanctions – Economic Sanctions

The European Union has also amended aspects of its pre-existing Russia-related economic sanctions regime,
including Council Regulation (EU) No 833/2014 of 31 July 2014, by including several additional restrictions on
trade with Russia and several rounds of additional listings.

Broadly comparable to U.S. sectoral sanctions, EU economic sanctions prohibit certain trade with Russia
(jurisdictional hook) and/or those specifically listed.

Also EU economic sanctions and respective listings are closely aligned with the U.S. and the UK, yet again
timing of the measures and listings varies.

EU economic sanctions regime also includes measures that would, in the United States, be addressed via
export control measures. The export control restrictions on dual-use items were recently expanded to cover
exports generally to Russia, rather than just exports for military end use or military end users in Russia.

New export control restrictions were implemented for goods and technology in the aviation and space
industry as well as for certain sensitive technologies and services that can be used for, inter alia, oil production
and exploration. Recently, maritime navigation and radio communication technology have been restricted as
well.

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 EU Sanctions – Economic Sanctions

Specific additional measures to date include:

Comprehensive economic sanctions were implemented to ban trade with the Donetsk and Luhansk regions
(comparable to those sanctions implemented regarding Crimea in 2014).

Comprehensive economic sanctions were also implemented to ban transactions with the Russian Central Bank
and the Central Bank of Belarus.

Additional targeted economic sanctions were implemented to limit access to EU primary and secondary
capital markets for certain Russian banks and companies and, recently, to (further) restrict access to the
capital and financial markets and services of the European Union.

Further, Bank Otkritie, Novikombank, Promsvyazbank (PSKBI.MM), Bank Rossiya, Sovcombank, VTB (VTBR.MM)
and VEB will be cut-off from SWIFT access by 12 March 2022. SWIFT access restrictions on Belarusian banks
Belagroprombank, Bank Dabrabyt and the Development Bank of the Republic of Belarus will follow by 20
March 2022.

Of note, EU member states may and have unilaterally implemented further measures, including financial and
economic sanctions.

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 Russian Counter-Sanctions – Possible Enhancement of
Compliance Program

Enhancement 1: Manage external sanctions & export control-related

Compliance
Controlling
communication

Compliance
Compliance Targets
Step 1: Identify respective external statements, such as published
Communication
statements on websites and Annual Reports.
Compliance Culture
Step 2: Undertake initial risk assessment to identify contradicting
Compliance Compliance
statements (e.g., “we fully comply with U.S., UK, EU and Russian export
Program Organization control law everywhere we work”).
Compliance Risks Step 3: Devise appropriate governance enhancements to duly manage
external sanctions & export control compliance-related communication.

Enhancement 2: Manage internal sanctions & export control-related policies & compliance management programs
Step 1: Identify respective internal statements, such as global sanctions and export control policies, trainings, and
acknowledgements.
Step 2: Undertake initial risk assessment to identify contradicting statements (e.g., “we must fully comply with U.S. and
Russian export control law everywhere we work.”).
Step 3: Devise appropriate governance enhancements to duly manage internal sanctions & export control compliance-
related communication.

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Major UK Developments
 UK Sanctions

So far, the UK has –

• Agreed to exclude a number of Russian banks from SWIFT. Not yet done.
• Announced its intention to introduce measures targeting the Russian Central Bank. Not yet done.
• Designated a number of key Russian entities. Broadly on par with EU.
• Designated a number of Russian individuals, including Putin, Lavrov and a range of oligarchs, military and business figures. Lagging behind
EU designations until today, when a further group of highly significant figures were designated – Deripaska, Abramovich, etc.
• Introduced new legislation to amend/expand existing Russian sanctions – The Russia (Sanctions) EU Exit) Regulations 2019:
‒ The Russia (Sanctions) (EU Exit) (Amendment) (No 2) Regulations 2022 : expands existing capital markets restrictions and existing debt
restrictions; introduces a prohibition on a UK credit/financial institution establishing or continuing a correspondent banking relationship
with a designated person (or certain financial institutions owned/controlled by such a person). UK credit/financial institutions are also
prohibited from processing sterling payments to, from or via, a designated person (or financial institution owned by such a person).
‒ The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations : expands on the existing restrictions on military and dual-use items to
also cover “critical industry goods” (electronics, IT, telecoms, info security, sensors and lasers, navigation, avionics, marine, aerospace,
propulsion).
‒ The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations : imposes shipping sanctions on Russian vessels from accessing UK
ports.
‒ The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations : imposes restrictions on the provision of financial services relating to
foreign exchange reserve and asset management for the Central Bank of the Russian Federation, National Wealth Fund of the Russian
Federation, Ministry of Finance of the Russian Federation, and persons owned or controlled or acting on behalf of the three entities.
‒ The Russia (Sanctions) (EU Exit) (Amendment No. 6) Regulations : imposes aviation restrictions.
• UK has been lagging the United States and EU until today (and still is on certain leading Russian business figures). A fair question is “why?”
 UK Sanctions - licensing

• General licences issued in respect of a range of the newly-introduced restrictions, notably regarding:
‒ The continued operation of Chelsea Football Club following the designation of Roman Abramovich.
‒ VTB Bank (allows for a 30-day wind-down for positions involving VTB Bank).
‒ Restrictions on dealing in transferable securities and money market instruments of certain Russian institutions (seven day wind-down re
new sanctions on sovereign debt, loans and MMIs).
‒ Sberbank (30-day wind-down for clearing and correspondent banking restrictions).
‒ Relevant energy products (extends above Sberbank wind-down until 24 June re clearing and correspondent bank prohibitions, where
those payments relate to “relevant energy products” – crude oil, gas and petroleum products).
‒ VTB Bank and any of its UK subsidiaires – allows anything to be done by, or on behalf of a Relevant Authority for the purposes of the
statutory functions of that authority as they relate to prudential supervision or protecting, maintaining or enhancing the stability of the
financial system of the UK.
‒ Any UK subsidiary of VTB – allows payments for basic needs (ie payment of tax); reasonable fees arising from the routine
holding/maintence of its frozen funds and economic resources; reasonable professional fees for the provision of legal services.
‒ Bank Otkritie, Promsvyazbank, Bank Rossiya, Sovcombank and VEB – allows for a 30-day wind-down of positions involving the foregoing
entities and their subsidiaries.
‒ Sberbank – wind down of positions (allows for the provision of financial services to Sberbank or a subsidiary for the purposes of winding
down that activity).
• Again, UK has been lagging other leading jurisdictions on licensing.
• UK appears responsive to concerted industry-led efforts to secure general licences.
Developments in Asia
 Other Sanctions in Asia

Acting in close coordination with the U.S., UK and the EU, several countries in Asia have also announced
autonomous sanctions against Russia.

• Imposed or extended asset freezes and travel bans against dozens of individuals and
entities, including a number of other Russian public officials and military leaders, and
certain entities in the defense, financial services and information sectors.
• Extended to the Donetsk and Luhansk regions of Ukraine the existing export and other
commercial restrictions applied to Crimea and Sevastopol.
• Announced restrictions on transactions involving securities and other similar financial
instruments issued by several key Russian financial institutions.

• Travel bans and asset freezes for specified Russian persons, including persons linked to the
Russian military and individuals from the Donetsk and Luhansk region.
• Prohibition on imports from the Donetsk and Luhansk regions.
• Restriction on exports to persons linked to the Russia military and of certain high-tech goods
such as semiconductors.
• Prohibitions on the issuance or dealing in new Russian sovereign debt in the primary or
secondary markets.
• Asset freezes of certain Russian financial institutions.

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Other Sanctions in Asia

• Asset freezes on VTB, VEB, Promsvyazbank and Bank Rossiya.

• Export controls and prohibitions on export financing.
• Capital raising restrictions related to the Russian government and central bank.
• Restrictions on financing of activity involving specific sectors in Donetsk and Luhansk
regions.
• Restriction on facilitating related cryptocurrency transactions.
• Forthcoming regulations will apply to all financial institutions in Singapore.

• A ban on exports to Russia of strategic items including electronics, semiconductors,

computers, information and communications, sensors and lasers, navigation and avionics,
and marine and aerospace equipment.
• Blocks of certain Russian banks’ access to SWIFT.

• Travel bans against Russian government officials and other individuals associated with the
invasion of Ukraine.
• Prohibition on exports of goods to Russian military and security forces.

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 Other Issues and What’s Next?

• Energy

• Control – When is an entity “controlled” by a EU/UK asset-freeze target?

• Licensing

• Payments

• Russia’s counter-measures

• Oligarchs

• AML

• Enforcement

• Repossessions, exit from Russia, contract terminations, litigation

• China

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Additional Resources
Additional Resources

• Client Alert | United States Responds to the Crisis in Ukraine with Additional
Sanctions and Export Controls

• Client Alert | US and Allies Announce Sanctions on Russia and Separatist

Regions of Ukraine
 David A. Wolber
32/F Gloucester Tower, The Landmark, 15 Queen's Road Central, Hong Kong, Hong Kong
Tel +852 2214 3764
DWolber@gibsondunn.com

David A. Wolber is a Registered Foreign Lawyer (New York) in Hong Kong and of counsel in the Hong Kong office of Gibson, Dunn & Crutcher. He is a
member of the Firm’s International Trade Practice Group.
Mr. Wolber assists clients around the world in understanding and navigating complex legal, compliance, reputational, political and other risks arising
out of the interplay of various international trade, national security and financial crime laws and regulations, with particular expertise advising
clients on economic and trade sanctions, export controls, foreign direct investment controls/CFIUS, anti-money laundering (“AML”) and anti-bribery
and anti-corruption (“ABC”) laws and regulations.
Mr. Wolber routinely advocates on behalf of clients seeking trade-related licenses or advisory opinions, responding to governmental inquiries or
subpoenas, filing self-disclosures related to potentially non-compliant activity, and dealing with formal regulatory investigations or enforcement
actions.
Mr. Wolber resumed his practice at Gibson Dunn in 2022 after taking a five-year hiatus to serve as in-house counsel to two major global financial
institutions. From 2019 to 2022 Mr. Wolber served as global financial crime counsel for HSBC, located in Hong Kong, where he advised the bank
globally on compliance and risk mitigation strategies associated with various jurisdictions’ sanctions, export controls, AML, ABC and national
security laws and regulations, with particular focus on such issues affecting the bank in Asia. During his tenure with HSBC, Mr. Wolber played a key
role in advising and helping to guide the bank through the significant challenges posed to global financial institutions by the rising tensions in US-
China relations and the related proliferation of law, regulation and political action in the US, Hong Kong and the People’s Republic of China. From
2017 to 2019, Mr. Wolber acted in a similar capacity at MUFG Bank, serving as the bank’s global financial crime counsel located out of New York.
Prior to becoming an attorney, Mr. Wolber spent more than 10 years in business strategy and development roles at Big Four accounting firms and
major U.S. law firms.
Mr. Wolber earned his Juris Doctor magna cum laude from Georgetown University Law Center in 2011. He received a Master of Science in Foreign
Service from Georgetown University in 1997, where he focused on International Trade and Asian Political Economy, and his Bachelor of Arts from
Rockhurst College in 1994. Mr. Wolber is a member of the New York State and District of Columbia Bars.

26
 Patrick Doris
Telephone House, 2-4 Temple Avenue, EC4Y 0HB London, United Kingdom
Tel +44 (0)20 7071 4276
PDoris@gibsondunn.com

Patrick Doris is a partner in Gibson Dunn’s Dispute Resolution Group in London, where he specialises in global white-collar investigations,
commercial litigation and complex compliance advisory matters.

Mr. Doris’ practice covers a wide range of disputes, including white-collar crime, internal and regulatory investigations, transnational litigation, class
actions, contentious antitrust matters and administrative law challenges against governmental decision-making.

Mr. Doris handles major cross-border investigations in the fields of bribery and corruption, fraud, sanctions, money laundering, financial sector
wrongdoing, antitrust, consumer protection and tax evasion.

Mr. Doris’ recent commercial disputes experience has extended to advising corporations, UK public bodies and sovereign states in claims in courts
and tribunals in the UK and around Europe. He has particular expertise in antitrust cases, human rights disputes and collective actions.

Mr. Doris is recognised by Legal 500 UK 2022 in the field of Regulatory Investigations and Corporate Crime. He is also ranked as a leading individual
in the field of Administrative and Public Law, in which clients have noted his: “…exceptional contribution to … work to decriminalise homosexuality
worldwide”. Clients describe him as “totally committed, a great manager and really goes the extra mile” and “outstanding, has tremendous
judgment, works exceptionally hard and always gives the impression that he is 100% dedicated to and focused on your case”. He is also ranked for
International Arbitration and Litigation (White Collar) in the Lawdragon 500 Global Litigation Lawyers guide 2021.

Mr. Doris earned his LL. M. (first class) in European Law in 1996; and received his BA in Law in 1994 from Trinity Hall, Cambridge University. Before
entering private practice, Mr. Doris taught law at the University of Warwick and worked in the Criminal Division of the Law Commission of England
& Wales, the UK government’s primary law reform body. Mr. Doris speaks English, Spanish, French and Catalan, with recent experience of
conducting investigations in each of those languages.

27
 Christopher T. Timura
1050 Connecticut Avenue, N.W., Washington, DC 20036-5306 USA
Tel +1 202 887 3690
CTimura@gibsondunn.com

Christopher T. Timura is Of Counsel in the Washington D.C. office of Gibson, Dunn & Crutcher LLP and a member of the firm’s International Trade
Practice Group. Mr. Timura helps clients solve regulatory, legal and political problems that arise at the intersection of national security, trade, and
foreign policy, and to develop corporate social responsibility (CSR) and environmental, social, and governance (ESG) strategies, policies, and
procedures. His clients range from start-ups to Fortune 50 companies, and span industries including aerospace and defense, auto, energy (nuclear,
oil and gas, and renewable), chemicals, finance, infrastructure and development, information security, insurance, investment management and
advising, medical device, pharmaceuticals, private equity, semiconductors, telecommunications, and travel.
Mr. Timura counsels clients on compliance with U.S. and international customs, export controls, and economic sanctions law and represents them
before the departments of State (DDTC), Treasury (OFAC and CFIUS), Commerce (BIS), Homeland Security (CBP and ICE), and Justice in voluntary and
directed disclosures, civil and criminal enforcement actions and investment reviews. Working with in-house counsel, boards, and other business
personnel, he helps to identify and leverage existing business processes to integrate international trade compliance, and CSR-related data gathering,
analysis, investigation, and reporting throughout client business operations. In M&A and other transactions, he conducts expedited diligence on
international trade compliance and CSR issues and supports business and compliance teams as they work to spin off or integrate business
operations in new organizations.
Mr. Timura also assists clients with the development of effective international trade compliance-, trade licensing-, and CSR-strategies to support
global R&D, supply chain, and customer bases. On a pro bono basis, Mr. Timura assists clients with immigration issues and works with several
international rule of law training NGOs on the investigation and enforcement of anti-human trafficking and forced labor laws, wildlife trafficking
laws, and on related legislative reform.
Mr. Timura received his J.D. from the University of Michigan Law School, where he served as an articles editor of the Michigan Journal of
International Law and received the William W. Bishop Jr. Award for his performance in the international law curriculum. In 2001, he served as a law
clerk to a member of the United Nations International Law Commission. Mr. Timura also earned a Ph.D. in cultural anthropology at the University of
Michigan.

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 Richard W. Roeder
Hofgarten Palais, Marstallstrasse 11, 80539 Munich, Germany
Tel +49 89 189 33-218
RRoeder@gibsondunn.com

Richard Roeder is a senior associate in the Munich office of Gibson, Dunn & Crutcher. He is a member of the firm's International Trade, White Collar
Defense, and Investigations and FCPA, as well as the Transactional Practice Groups Mergers and Acquisitions, Private Equity, Latin America, and Capital
Markets. Mr. Roeder focuses on international trade compliance and white collar investigations, as well as transactional regulatory risk assessments
and advises clients from various industries in the areas of sanctions, anti-money-laundering and anti-corruption compliance. Mr. Roeder focuses on
clients in the banking, insurance, automotive, mining, oil and gas, healthcare and information technology industries.

In 2018, Mr. Roeder was seconded to our Washington, D.C. office where he worked with our U.S. sanctions and export control team and specifically
assisted our clients in managing the challenges posed by the divergence between U.S. and EU economic and financial sanctions (e.g. regarding the EU
Blocking Statute).

He is the author, among other books, with Washington D.C. partner Adam Smith and former counsel Stephanie Connor, of "U.S., EU, and UN
Sanctions: Navigating the Divide for International Business" (2019) and author of "Foreign Mining Investment Law" (2016) and, with Munich partner
Michael Walther, co-author of the renowned International Legal Guide to Sanctions, there focusing on EU sanctions and German export controls.

Mr. Roeder has recently been featured in the Legal 500 Germany 2022 as an excellent advisor on any issues related to economic and financial
sanctions as well as export control law. Market participant characterized Mr. Roeder as a responsive lawyer with a distinguished sense for future
developments and challenges his clients face, providing them with state of the art business information and sophisticated legal advice.

Prior to joining Gibson Dunn, Mr. Roeder was a fellow of what today is called the Mercator Fellowship on International Affairs, working for the German
Ministry of Economics, the German Foreign Service, the European Union and the United Nations Development Program.

Mr. Roeder received his law degree (first state exam) from Bucerius Law School, Hamburg, Germany and undertook his clerkship (culminating in the
second state exam) at the High Court of Munich, Germany. He holds a Master of Laws (LL.M.) degree from the University of California, Berkeley, USA,
a Master of International Studies (M.I.S.) degree from the University of Queensland, Australia and earned his doctoral degree on Foreign Mining
Investment Law from the University of Cologne, Germany.

Mr. Roeder speaks German, English, French, and Spanish.

Gibson Dunn 29
 Claire Yi
1050 Connecticut Avenue, N.W., Washington, DC 20036-5306 USA
Tel +1 202.887.3644
CYi@gibsondunn.com

Claire Yi is an associate in the Washington, D.C. office of Gibson, Dunn & Crutcher. She is a member of the firm’s International Trade and White
Collar Defense and Investigations Practice Groups.

Ms. Yi received her Juris Doctor, magna cum laude, from Harvard Law School, where she was an Articles Editor for Harvard International Law
Journal. During law school, she served as an intern for the Compliance and Business Risk Department at the World Bank-International Finance
Corporation, for the Office of the Inspector General at the State Department, and for the Office of the Legal Adviser at the State Department. Ms. Yi
graduated from Wellesley College, where she received a Bachelor of Arts, summa cum laude, with Honors in Peace and Justice Studies. Prior to
attending law school, Ms. Yi was a Legal Assistant for a global law firm in New York City.

Ms. Yi is fluent in Korean and conversant in French. Ms. Yi is admitted to practice in the District of Columbia and the State of New York.

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