Frequently Asked Questions

1186. What activities are considered prohibited “IT support services” and “cloud-based services” for enterprise management software and design and manufacturing software (collectively “Covered Software”) under the determination, “Prohibition on Certain Information Technology and Software Services”, pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”)?

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. How does OFAC intend to interpret the following terms in the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O.) 14071 (the “IT and Software Services Determination”): “enterprise management software,” “design and manufacturing software,” “cloud-based services,” “information technology support services,” and “information technology consultancy and design services”?

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

1164. What prohibitions has OFAC implemented with respect to diamonds and diamond jewelry under the Russian Harmful Foreign Activities Sanctions program?

1164 … On March 11, 2022, the Biden Administration issued Executive Order (E.O.) 14068 , prohibiting the importation into the United States of non-industrial diamonds of Russian Federation origin. See FAQs 1019 and 1027 for the definition of Russian Federation origin and non-industrial diamonds,… Read more

1165. What does the determination “Prohibitions Related to Imports of Certain Categories of Diamonds” pursuant to Executive Order (E.O.) 14068 (the “Diamonds Determination”), prohibit?

1165 … The Diamonds Determination prohibits the importation and entry into the United States of two categories of diamonds, effective on the dates indicated below. Effective March 01, 2024, the Diamonds Determination prohibits the importation of non-industrial diamonds that were mined, extracted,… Read more

1166. What does the determination “Prohibitions Related to Imports of Diamond Jewelry and Unsorted Diamonds of Russian Federation Origin and Diamond Jewelry and Unsorted Diamonds Exported From the Russian Federation” pursuant to Executive Order (E.O.) 14068 (the “Diamond Jewelry and Unsorted Diamonds Determination”), prohibit?

1166 … The Diamond Jewelry and Unsorted Diamonds Determination prohibits the importation and entry into the United States of diamond jewelry and unsorted diamonds of Russian Federation origin, as well as diamond jewelry and unsorted diamonds that were exported from the Russian Federation. For… Read more

1168. What action did Treasury take on April 12, 2024 with regards to aluminum, copper, and nickel of Russian Federation origin?

1168 … On December 6, 2023 , and February 24, 2024 , the G7 Leaders issued statements signaling their intent to reduce Russia’s revenues from metals. On April 12, 2024, in coordination with the United Kingdom, the United States issued two new prohibitions that will further disrupt the revenue that… Read more

1169. What is prohibited by the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”)?

1169 … The Metals 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 the following categories of services to any person located in the Russian Federation: warranting… Read more

1170. For the purposes of the determination “Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114, (the “Metals Import Determination”) and the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”), what is meant by the terms “aluminum,” “nickel,” and “copper”?

1170 … For the purposes of the Metals Import Determination and the Metals Services Determination , OFAC anticipates publishing regulations defining “aluminum,” “nickel,” and “copper” to include articles or products defined at the following Harmonized Tariff Schedule of the United States (HTSUS)… Read more

1171. Do the determinations “Prohibitions Related to Imports of Aluminum, Copper, and Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14068, as amended by E.O. 14114, (the “Metals Import Determination”) and the determination “Prohibitions on Certain Services for the Acquisition of Aluminum, Copper, or Nickel of Russian Federation Origin” pursuant to Executive Order (E.O.) 14071 (the “Metals Services Determination”) apply to aluminum, copper, or nickel that has been incorporated or substantially transformed into other products outside of the Russian Federation?

1171 … No. FAQ 1019 clarifies that, for purposes of E.O. 14068 , as amended by E.O. 14114 , and the Metals Services Determination , the term “Russian Federation origin” excludes “any Russian Federation origin good that has been incorporated or substantially transformed into a foreign-made product… Read more

1146. What does Executive Order (E.O.) 14114, “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities,” do?

1146 … E.O. 14114 amends E.O. 14024 and E.O. 14068 to further address the Russian Federation’s continued use of its military-industrial base to aid its effort to undermine security in countries and regions important to United States national security and to further counteract the Russian Federation… Read more

Frequently Asked Questions

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