OJSC CAPITAL BANK OF CENTRAL ASIA (hereafter CAPITAL BANK) is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis that it is and has been involved in obtaining a benefit from or supporting the Government of Russia through: (1) carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian financial services sector; (2) carrying on business of economic significance to the Government of Russia.