OFAC FAQ (Current) # 1185 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 12 2024

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TURBOFAC Commentary (309 words)

Notes:

1) While the term “information technology (IT) consultancy and design services” is not given a definition in OFAC’s FAQs, this FAQ provides examples of activities that fall within the scope of the term (which is unique to 6-12-24 Tech Services Determination). Of particular note, OFAC specifies that “the retail sale of off-the-shelf software” is not considered “information technology (IT) consultancy and design services,” and this also appears to fall outside the scope of the other portion of the 6-12-24 Tech Services Determination (see FAQ # 1186 and FAQ # 1187).

2) This FAQ addresses situations in which “services were provided to a company located in the Russian Federation that is not owned or controlled directly or indirectly by a U.S. person (Russian company)”. FAQ # 1188 addresses “providing services to persons located outside of the Russian Federation that...