OFAC FAQ (Current) # 1187 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 12 2024

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TURBOFAC Commentary (523 words)

Note common to FAQ # 1186 and FAQ # 1187

1) FAQ # 1187 defines terms found within the 6-12-24 Tech Services Determination. The determination applies to:

“the following categories of services: (1) [information technology (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],” where each of the bracketed terms have separate definitions given in FAQ # 1187.

FAQ # 1185 and FAQ # 1186 each provide examples of activities that, in light of FAQ # 1187, would meet the definition of “IT support services” and “cloud-based services” for “enterprise management software and design and manufacturing software”.

2) The definitions of the five bracketed terms are all unique to the 6-12-24 Tech Services Determination, and...