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1184. What action did Treasury take on June 12, 2024 with regards to prohibiting certain information technology (IT) and software-related services?
In line with G7 efforts to disrupt Russia’s defense industry’s reliance on western IT systems, on June 12, 2024, Treasury issued a determination that restricts the provision of certain IT and software-related services to Russia. The determination, “Prohibition on Certain Information Technology and Software Services,” issued pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”), prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of: (1) IT consultancy and design services; and (2) IT support services and cloud-based services for the following categories of software: enterprise management software and design and manufacturing software (collectively, “Covered Software”). The IT and Software Services Determination...
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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...