OFFICE OF FOREIGN ASSETS CONTROL
DETERMINATION PURSUANT TO SECTION 1(a)(ii) OF EXECUTIVE ORDER 14071
Prohibitions Related to Architecture Services and Engineering 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, and in consultation with the Department of State, I hereby determine that the prohibitions in section 1(a)(ii) of E.O. 14071 shall apply to the following categories of services: architecture and engineering. 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, or by a United States person, wherever...
1) This "determination" and the FAQs published concurrently therewith largely mimics OFAC's Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (Effective May 8, 2022) ("accounting, trust and corporate formation, and management consulting" services). 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) As with the May 8 determination, there is the service prohibition issued pursuant to 14071, along with a parallel designation authority (here Determination Pursuant to Section 1(a)(i) of Executive Order 14024 (Effective May 19, 2023)).
3) Note the very broad definition of “architecture and engineering” services found at FAQ # 1128.
4) Refer generally to General Note on E.O....