OFAC FAQ (Current) # 1188 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 12 2024

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TURBOFAC Commentary (323 words)

Notes:

1) Compare FAQ # 1059 (and see comments thereto), which is the “benefit of the services is ultimately received” / “indirect” FAQ in the context of the 5-8-22 Professional Services Determination, 5-19-23 Architecture and Engineering Services Determination and 9-15-22 Quantum Computing Services Determination. This FAQ provides examples of an “indirect” provision of services that are tech-specific, but the two FAQs appear to follow the same logic. Accordingly, this FAQ has some relevance for each of the other three service prohibitions discussed in FAQ # 1059.

2) As with FAQ # 1059, the two “not prohibited” examples provided are examples where the third country entity “has an office and employees in the third country and conducts business in this third country, and the services will not be reexported to the Russian parent company.” This is evidently enough to establish...