LICENSE No.

GLOMAG-2021-371648-1

GLOBAL MAGNITSKY SANCTIONS REGULATIONS

LICENSE

(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Pub. L. 114-328, Executive Order
13818, and 31 C.F.R. Parts 501 and 583.)

To: Arnold & Porter Kaye Scholer LLP

601 Massachusetts Avenue, N.W.
Washington, D.C. 20001
Attn: Baruch Weiss, Esq.

1. Based upon, inter alia, the information dated December 3, 2020, submitted on behalf of Mr. Dan
Gertler, to the Office of Foreign Assets Control, the transactions described herein are hereby
authorized.

2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms
and with all regulations, rulings, orders, and instructions issued under any of the authorities cited
above.

3. This License expires on January 31, 2022 and is not transferable. The transactions described in
this License are subject to the authorities cited above and any regulations and rulings issued pursuant
thereto. This License may be revoked or modified at any time. If this License was issued as a result
of willful misrepresentation it may be declared void from the date of its issuance or from any other
date.

4. This License does not authorize transactions prohibited by any law or regulation administered by
the Office of Foreign Assets Control other than those listed above.

5. This License does not excuse the Licensee(s) from the need to comply with any law or regulation
(including reporting requirements) administered by any other agency or the need to obtain any
required authorization(s) from any other agency.

OFFICE OF FOREIGN ASSETS CONTROL

Digitally signed by Andrea M.
Andrea M. Gacki
Date: 2021.01.15 18:44:22 -DQXDU\
Gacki
By____________________________________
-05'00' _____________
Andrea Gacki Date
Director
Attention is directed to, inter alia, 18 U.S.C. § 1001, 50 U.S.C § 1705, and Pub. L. 114-328 § 1263(f) for
provisions relating to penalties.
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SECTION 1 - AUTHORIZATION: Subject to the limitations and conditions herein, all

transactions and activities otherwise prohibited by the Global Magnitsky Sanctions Regulations, 31
C.F.R. part 583, that are necessary to the following are authorized:

(a) All transactions and activities involving Mr. Dan Gertler, Mr. Pieter Albert Deboutte, Fleurette
Properties Limited, Fleurette Holdings Netherlands B.V., Gertler Family Foundation, Oil of DR
Congo SPRL, Jarvis Congo SARL, International Diamond Industries, D.G.D. Investments Ltd.,
D.G.I. Israel Ltd, Proglan Capital Ltd, Emaxon Finance International Inc., Africa Horizons
Investment Limited, Caprikat Limited, Foxwhelp Limited, Caprikat and Foxwhelp SARL, Lora
Enterprises Limited, Zuppa Holdings Limited, Orama Properties Ltd, DGI Mining Ltd, and
Rozaro Development Limited (the “December 2017 Companies”), as well as Moku Mines D’or
SA, Moku Goldmines AG, Fleurette Energy I B.V., Fleurette Africa Resources I B.V., African
Trans International Holdings B.V., Fleurette African Transport B.V., Oriental Iron Company
SPRL, Iron Mountain Enterprises Limited, Sanzetta Investments Limited, Almerina Properties
Limited, Kitoko Food Farm, Karibu Africa Services SA, and Ventora Development Sasu (the
“June 2018 Companies”), which are individuals or entities designated pursuant to Executive
Order 13818, or any entity in which Mr. Gertler, Mr. Deboutte, the December 2017 Companies,
or the June 2018 Companies own, directly or indirectly, a 50 percent or greater interest
(collectively “the Licensees”);

(b) All transactions and activities by AIG, on behalf of AIG Europe Limited, Netherlands; American
Express Travel Related Services Company Co. Inc.; Bank of China Limited; Bloomberg LP;
Citibank NA; Deutsche Bank Trust Company Americas; Bank of New York Mellon; and Wells
Fargo Bank National Association (collectively, the “Bank Licensees”) involving the unblocking
of all property and interests in property of the Licensees in the possession or control of the Bank
Licensees blocked as of the date of the License; and

(c) Establishing accounts with U.S. financial institutions for the Licensees for use in connection with
transactions and activities authorized in SECTION 1(a).

SECTION 2 - CONDITION: Prior to engaging in activity authorized in SECTION 1(c), Licensees

are required to provide a copy of this License to the applicable U.S. financial institution.

SECTION 3 - WARNINGS: (a) Except as authorized in SECTION 1, this License does not
authorize the transfer of any blocked property, the debiting of any blocked account, the entry of any
judgment or order that effects a transfer of blocked property, or the execution of any judgment against
property blocked pursuant to any Executive order or statute, or 31 C.F.R. Chapter V.

(b) Any transfer of funds through the U.S. financial system pursuant to the authority set forth in
SECTION 1 hereof should reference the number of this License to avoid the blocking or rejection of
the transfer.

SECTION 4 - RECORDKEEPING AND REPORTING REQUIREMENTS: (a) The Licensees

are subject to the recordkeeping and reporting requirements of, inter alia, 31 C.F.R. §§ 501.601 and
501.602, including the requirement to maintain full and accurate records concerning the activities
undertaken pursuant to this License for a period of five years from the date of each transaction.
LICENSE No. GLOMAG-2021-371648-1 Page 3 of 3

(b) Any U.S. financial institution that has established any account pursuant to SECTION 1(c) must
provide the name and address of the financial institution, the name of the account holder, and the
account number to OFAC within 10 business days of the establishment of the account.

(c) The Licensees are required to submit detailed reports to OFAC every 90 days from the issuance
of the License providing information on any activities undertaken pursuant to the License. In the
event that no activities occur during the reporting period, a statement is to be filed to that effect. The
reports are to be mailed to: Licensing Division, Office of Foreign Assets Control, U.S. Department
of the Treasury, 1500 Pennsylvania Avenue, N.W., The Freedman’s Bank Building, Washington,
D.C. 20220, and are to refer to this License No. GLOMAG-2021-371648-1.

SECTION 5 - PRECEDENTIAL EFFECT: The authorization contained in this License is limited

to the facts and circumstances specified in the Application.
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