Alexander Vladimirovich FROLOV (hereafter FROLOV) is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis of the following grounds: (1) FROLOV is a former director of Evraz plc; in this role, FROLOV has been involved in obtaining a benefit from or supporting the Government of Russia by working as a Director of an entity carrying on business in sectors of strategic significance to the Government of Russia, namely, the Russian extractives, transport and construction sectors; (2) FROLOV is a former CEO of Evraz plc, in this role, FROLOV has been involved in supporting the Government of Russia by working as a manager of an entity carrying on business in sectors of strategic significance to the Government of Russia, namely, the Russian extractives, transport and construction sectors; (3) FROLOV is involved in obtaining a benefit from or supporting the Government of Russia by owning or controlling directly or indirectly (within the meaning of reg. 7 (2)) Evraz plc, an entity carrying on business in sectors of strategic significance to the Government of Russia, namely, the Russian extractives, transport and construction sectors. |