DETERMINATION PURSUANT TO SECTION 1(a)(ii) OF EXECUTIVE ORDER 14071
Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services
Pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order (E.O.) 14071 of April 6, 2022 (“Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression”) and 31 CFR § 587.802, the Director of the Office of Foreign Assets Control, in consultation with the Department of State, hereby determines that the prohibitions in section 1(a)(ii) of E.O. 14071 shall apply to the following categories of services: accounting, trust and corporate formation, and management consulting. As a result, the following activities are prohibited, except to the extent provided by law, or unless licensed or otherwise authorized by the Office of Foreign Assets Control:
the exportation, reexportation, sale, or supply, directly or indirectly, from the United States,...
1) See General Note on E.O. 14071-Based Prohibitions on the Exportation of Certain Services to Persons Located in Russia (System Ed. Note) for comments on the Determination and related FAQs and guidance.
2) This sectoral determination was issued concurrently with Determination Pursuant to Executive Order 14024 of April 15, 2021 (Effective May 8, 2022), which gave OFAC the authority to sanction persons for "operating in" the "the accounting, trust and corporate formation services, and management consulting sectors of the Russian Federation economy". That determination is about designation criteria, or "secondary sanctions" (in the loose sense of the term). This determination, by contrast, has the effect of imposing primary sanctions prohibitions with respect to "accounting, trust and corporate formation, or management consulting services." This imposes a prohibition with respect to Russia that is, as of 5-8-22, completely unique among...