OFAC FAQ (Current) # 1038 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: May. 11 2022

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TURBOFAC Commentary (174 words)

Notes:

1) Read along with FAQ # 1037. This FAQ defines the covered terms in a manner that is virtually identical to the definitions used for the purposes of the EO 14071 primary sanctions prohibitions (see FAQ # 1034), except that, perhaps unintentionally, the definitions at FAQ # 1034 appear broader through use of "services related to" covered activities.

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” –...