Section 1(a)(ii) of E.O. 14071 prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, to any person located in the Russian Federation. As of May 19, 2023, categories of services identified pursuant to E.O. 14071 include:
|Categories of Services||Date of Determination||Date of Effectiveness||Definitions|
|accounting||May 8, 2022||June 7, 2022||FAQ 1034|
|trust and corporate formation services|
|quantum computing||September 15, 2022||October 15, 2022||FAQ 1084|
|trading/commodities brokering, financing, shipping, insurance including reinsurance and protection and indemnity, flagging, and customs brokering services as they relate to the maritime transport of crude oil of Russian Federation origin||December 5, 2022||December 5, 2022||OFAC Guidance on Implementation of the Price Cap Policy|
|trading/commodities brokering, financing, shipping, insurance including reinsurance and protection and indemnity, flagging, and customs brokering services as they relate to the maritime transport of petroleum products of Russian Federation origin||February 5, 2023||February 5, 2023|
|architecture||May 19, 2023||June 18, 2023||see below|
OFAC expects to promulgate regulations that define the terms architecture services and engineering services consistent with the following:
Architecture services include advisory services; pre-design services; design services, including schematic design, design development, and final design; contract administration services; combined architectural design and contract administration services; including post construction services; and all other services requiring the expertise of architects. The prohibition applies to such services as they relate to residential, institutional, leisure, commercial, and industrial buildings and structures; recreational areas; transportation infrastructure; land subdivisions; and not necessarily related to a new construction project. The term also includes urban planning services (i.e., land use, site selection, and servicing of land for systemic, coordinated urban development) and landscape architectural services. OFAC intends to interpret this term consistent with UN Central Product Classification (CPC) Codes 86711-86704, 86719, and 86741-86742.
Engineering services include assistance, advisory, consultative, design, and recommendation services concerning engineering matters or during any phase of an engineering project. Engineering design services may be for: the construction of foundations and building structures (i.e., structural engineering); mechanical and electrical installations for buildings; the construction of civil engineering works; industrial processes and production; or other engineering designs, such as those for acoustics, vibration, traffic control systems, or prototype development for new products. The term additionally includes geotechnical, groundwater, and corrosion engineering services; integrated engineering services, such as those for transportation infrastructure or other projects; engineering-related scientific and technical consulting services, including geological, geophysical, geochemical, surface or subsurface surveying, and map making services; testing and analysis services of chemical, biological, and physical properties of materials or of integrated mechanical and electrical systems; and technical inspection services. OFAC intends to interpret this term consistent with UN CPC Codes 86721-86727, 86729, 86731-86733, 86739, 86751-86754, 86761-86764, and 86769. Additionally, OFAC does not consider maritime classification services to be subject to the prohibition, as is consistent with the OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin.