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1067. Do the prohibitions imposed by the determination 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” (“the determination”), prohibit U.S. persons from providing software related to accounting, management consulting, or trust and corporate formation to persons located in the Russian Federation?
The determination does not prohibit U.S. persons from exporting, reexporting, selling, or supplying, directly or indirectly, software to the Russian Federation, nor does the determination prohibit U.S. persons from providing services associated with the export of such software, such as software design and engineering, provided that such associated services do not fall within the categories of management consulting, accounting, or trust and corporate formation.
For example, the following scenario describes activities that would not be prohibited under the determination:
• A U.S. software company signs a contract...
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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...