OFAC FAQ (Current) # 1084 - Russian Harmful Foreign Activities Sanctions

Date issued: Sep. 15 2022

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TURBOFAC Commentary (150 words)

Notes:

1) Compare FAQ # 1034 (the leading FAQ defining "accounting, trust and corporate formation, and management consulting services" for the purposes of the determination of May 8, 2022 made pursuant to EO 14071. "[S]ervices when related to quantum computing" is capable of an extremely broad reading, given that it is not specified how closely “related” the services must be to quantum computing in order to be prohibited, but compare FAQ # 1067, in which OFAC takes a pragmatic view of the term “related to” as it appears in FAQ # 1034.

2) See FAQ # 1086 for the designation criterion equivalent of this FAQ.

3) See 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...