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

Date issued: Jun. 09 2022

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TURBOFAC Commentary (327 words)

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 services is prohibited by EO 14071.

It is presumably not the case that a U.S. person could provide bespoke software with an aim of replicating the sort of live body professional services that are within the scope of the May 8, 2022 prohibition. However, here, notwithstanding that "internet services" are generally regarded by OFAC as "services," OFAC clarifies that the May 8, 2022 prohibition is not designated to capture the provision of software. OFAC does not...