OFAC FAQ (Removed) # 1067 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 09 2022

Last substantive commentary amendment:
Jun. 12 2024

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TURBOFAC Commentary (404 words)

[6-12-24 update - FAQ removed on 6-12-24 in light of the issuance of the 6-12-24 Tech Services Determination. FAQ # 1185 specifies that it is prohibited to sign a “contract with a Russian company for the design and engineering of bespoke (i.e., custom-made) software that the Russian company uses for internal purposes.” There is, however, no reason to believe that the FAQ no longer reflects OFAC's view concerning the scope of the May 8, 2022 prohibition].

Notes:

1) Read in conjunction with FAQ # 1034, defining "management consulting services" broadly, to "include[] services related to strategic business advice; organizational and systems planning, evaluation, and selection; development or evaluation of marketing programs or implementation; mergers, acquisitions, and organizational structure; staff augmentation and human resources policies and practices; and brand management." Note in addition that the "facilitation" of the provision of any such...