Frequently Asked Questions

1184 … In line with G7 efforts to disrupt Russia’s defense industry’s reliance on western IT systems, on June 12, 2024, Treasury issued a determination that restricts the provision of certain IT and software-related services to Russia.  The determination, “ Prohibition on Certain Information… Read more

1185 … IT consultancy and design services include the development and implementation of software, as well as assistance or advice relating to the development and implementation of software, including the supply and installation of bespoke software.  However, the retail sale of off-the-shelf… Read more

1186 … The IT and Software Services Determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of both IT support services and cloud-based services for the Covered Software to a person… Read more

1187 … OFAC expects to promulgate regulations that define or interpret these terms as follows: The term enterprise management software means the following types of software:  enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI), supply chain… Read more

1188 … No, provided that the provision of services is not an indirect export to a person located in the Russian Federation.  For the purposes of the IT and Software Services Determination , OFAC interprets the “indirect” provision of the prohibited services to include when the benefit of the… Read more