OFAC FAQ (Current) # 1064 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 09 2022

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TURBOFAC Commentary (95 words)

Notes:

1) "[E]executive search and vetting services" evidently qualify as "staff augmentation" (at a minimum).

Query: does this apply only to services provided to Russian entities, or also Russian individuals that contract with executive search agencies? In these cases, which of the covered services are actually provided to the Russian individual itself?

2) See section IV(b) 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.