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1038. For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the terms “accounting,” “trust and corporate formation services,” and “management consulting” sectors of the Russian Federation economy?
For the purposes of the determination of May 8, 2022 made pursuant to E.O. 14024, OFAC interprets the following terms to include activities related to products and services in or involving the Russian Federation in the following:
• “Accounting sector” – includes the measurement, processing, and evaluation of financial data about economic entities.
• “Trust and corporate formation services sector” – includes assisting persons in forming or structuring legal persons, such as trusts and corporations; acting or arranging for another person to act as directors, secretaries, administrative trustees, trust fiduciaries, registered agents, or nominee shareholders of legal persons; providing a registered office, business address, correspondence...
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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” –...