General Note on E.O. 14071-Based Prohibitions on the Exportation of Certain Services to Persons Located in Russia (System Ed. Note)

Last substantive commentary amendment:
Apr. 14 2024

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TURBOFAC Commentary (4788 words)

(I) BACKGROUND

(II) SCOPE OF THE PROHIBITIONS - FUNDAMENTALS

....(a) The Meaning of "Person Located in the Russian Federation"
.........(i) "Ordinarily Resident"
.........(ii) "In the Russian Federation"
.........(iii) "Entities Incorporated or Organized Under the Laws of the Russian Federation or Any Jurisdiction Within the Russian Federation"
....(b) The Notion of an "Indirect" Exportation or Supply of Services "to" a Person Located in the Russian Federation
.........(i) The "Benefit of the Services is Ultimately Received"
.........(ii) The Notion of Providing a Service "To" a Person Located in the Russian Federation

(III) FACILITATION IN GENERAL, "SOFTWARE" AND "EDUCATION" AS "FACILITATION"

(IV) SCOPE OF SERVICES COVERED
....(a) "Accounting Services"
....(b) Management Consulting Services ("MCS")
....(c) Trust and Corporate Formation Services ("T&CFS")
....(d) Quantum Computing Services

V. THE EXCLUSIONS
....(a) The "Owned or Controlled...by a United States Person" Exclusion
....(b)...