Article 4 Freezing prohibitions

(1)

The provisions of this article apply in relation to the following funds (“frozen funds”)—

(a)

funds owned, held or controlled by Andrey Lugovoy; and

(b)

funds owned, held or controlled by Dmitri Kovtun.

(2)

A person must not make frozen funds available to or for the benefit of a specified person.

(3)

A person must not make frozen funds available at the direction or instruction of a specified person.

(4)

A person must not deal with frozen funds.

(5)

For the purposes of this article, making funds available to or for the benefit of a specified person includes—

(a)

allowing him to withdraw from an account;

(b)

honouring a cheque payable to him;

(c)

crediting his account with interest;

(d)

releasing documents of title (such as share certificates) held on his behalf;

(e)

making available the proceeds of realisation of his property; and

(f)

making a payment to or for his benefit.

(6)

In this article “deal with” means—

(a)

use, alter, move, allow access to or transfer;

(b)

deal with in any other way that would result in any change in volume, amount, location, ownership, possession, character or destination; or

(c)

make any other change that would enable use, including portfolio management.