OFAC FAQ (Current) # 1034 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Sep. 15 2022

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TURBOFAC Commentary (488 words)

Notes:

1.1) See section IV of General Note on E.O. 14071-Based Prohibitions on the Exportation of Certain Services to Persons Located in Russia (System Ed. Note) for comments on the FAQ in the context of the relevant prohibitions in general.

1.2) Refer to Russia-related General License 35.

2) FAQ amended on 5-10-22 to (i) change in 1034/1038 definition of “accounting services” from “transfer of financial data” to “evaluation of financial data,” and (ii) the alteration to “management consulting services” described below:

May 8: “Management consulting services” – includes services related to strategic advice; organizational and systems planning, evaluation, and selection; marketing objectives and policies; mergers, acquisitions, and organizational structure; staff augmentation and human resources policies and practices; and brand management.

May 11: “Management consulting services” – includes services related to strategic
business advice; organizational and...