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1061. Do the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services, on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services,” and on May 19, 2023, “Prohibitions Related to Architecture and Engineering Services” (“the determinations”) prohibit U.S. persons from working as employees of entities located in the Russian Federation?
Not necessarily. Under the determinations, U.S. persons are prohibited from exporting, reexporting, selling, or supplying, directly or indirectly: management consulting; trust and corporate formation services; accounting services; quantum computing services; architecture services; and engineering services to persons located in the Russian Federation. Thus, U.S. persons are prohibited from providing these services to companies located in the Russian Federation (“Russian companies”) in their capacity as employees. However, the determinations do not prohibit U.S. persons from providing other services not covered by...
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1.1) See sections III and IV(b)-(c) 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) FAQ amended on 9-15-22 to add references to the Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (Effective September 15, 2022) (quantum computing-related).
1.3) FAQ amended on 5-19-23 to add “Prohibitions Related to Architecture and Engineering Services” in light of the issuance of Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (Effective June 18, 2023).
2) None of FAQ # 1058, FAQ # 1061 or FAQ # 1062 have been amended in light of the 6-12-24 Tech Services Determination, but this appears...