1169. What is prohibited by the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”)?
The Metals Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of the following categories of services to any person located in the Russian Federation: warranting services for aluminum, copper, or nickel of Russian Federation origin on a global metal exchange; and services to acquire aluminum, copper, or nickel of Russian Federation origin as part of the physical settlement of a derivative contract (collectively, “Covered Metals Acquisition Services”). This determination does not apply to services related to aluminum, copper, or nickel of Russian Federation origin that was produced prior to April 13, 2024.
To ensure compliance with the...
1) This FAQ provides critical interpretive guidance concerning the scope of the 4-12-24 Services Determination (and, as it relates to the fourth paragraph, probably the 4-12-24 Import Determination as well).
2) For comments on the significance on this FAQ refer to sections II(c) and IV(d) of Consolidated Comment on the 4-12-23 Aluminum, Copper, and Nickel-Related Service and Import Prohibitions (System Ed. Note).