OFAC FAQ (Current) # 1184 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 12 2024

Last substantive commentary amendment:
Sep. 02 2024

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TURBOFAC Commentary (213 words)

Notes:

1) This FAQ introduces the 6-12-24 Tech Services Determination without providing much in the way of interpretive guidance beyond what is evident from the text of the determination, except to (i) clarify that Russia-related GL 6 and Russia-related GL 25 license against the Tech Services Determination, and, relatedly, (ii) to clarify that “[t]he aim of [the Tech Services Determination] is not to prohibit all activity relating to the provision of IT and software-related services to Russia”.

2) FAQ # 1184, FAQ # 1185, FAQ # 1186, FAQ # 1187, and FAQ # 1188 were all issued or last amended concurrently with the 6-12-24 Tech Services Determination.

3) OFAC states that “the importation from any country, or the exportation to any country of any information or informational...