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1086. For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “quantum computing sector of the Russian Federation economy”?
For the purposes of the determination of September 15, 2022 made pursuant to E.O. 14024, OFAC interprets the term “quantum computing sector of the Russian Federation economy” to include activities related to products and services in or involving the Russian Federation in research, development, manufacturing, assembling, maintenance, repair, sale, or supply of quantum computing, quantum computers, electronic assemblies thereof, or cryogenic refrigeration systems related to quantum computing. OFAC also interprets the term “quantum computing sector of the Russian Federation economy” to include any of the following services when related to quantum computing: infrastructure, web hosting or data processing services; custom computer programming services; computer systems integration design services; computer systems and data processing facilities management...
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1) See FAQ # 1084 for the services prohibition equivalent of this FAQ. The primary difference is that “quantum computing sector of the Russian Federation economy” includes the actual exportation of goods themselves, as opposed to just services related to such exportation, and it also apparently includes the receipt of goods from Russia.
The receipt of goods from non-sanctioned individuals is not prohibited by any OFAC-administered primary sanctions prohibition active as of the date on which this FAQ was issued. Does this mean that non-U.S. persons can be designated for such activities even though they aren’t prohibited for U.S. persons? Presumably note. See FAQ # 980 (“Moreover, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, where those transactions would not require a...