OFAC FAQ (Current) # 1192 - Russian Harmful Foreign Activities Sanctions

Date issued: Sep. 12 2024

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TURBOFAC Commentary (109 words)

Notes:

1) This FAQ, which explains the scope of the Commerce-related carveouts to the Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (Effective September 12, 2024) - Prohibition on Certain Information Technology and Software Services, was evidently issued to clarify (to the extent clarification was needed) that “authorized or licensed by the Department of Commerce” includes “Covered Software that is excluded by Commerce from license requirements in 15 CFR 746.8(a)(12).” OFAC was presumably receiving many inquiries about the prohibition as it applied to subsidiaries of friendly (Country Group A:5 and A:6) countries by people unaware of the nature of breadth of the EAR exclusion for such subsidies.