FFIs may be sanctioned for engaging in certain transactions, or providing any service, involving Russia’s military-industrial base. For example, FFIs may be sanctioned for conducting any significant transaction(s) for any person that has been blocked pursuant to E.O. 14024. FFIs may also be… Read more
In line with G7 commitments and in response to the Government of the Russian Federation’s continued efforts to reorient its economy and government resources to support its war effort, Treasury has updated its definition of Russia’s military-industrial base to include all persons blocked pursuant to… Read more
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’s… Read more
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 management (… Read more
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 located in… Read more
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 software,… Read more
General License (GL) 8J authorizes certain transactions “related to energy” (as defined in the GL; see also FAQ 977 ) involving the following entities (collectively, “Covered Entities”): State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB); Public Joint Stock… Read more
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 Technology… Read more
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 services is… Read more
On June 12, 2024, OFAC issued Russia-related general licenses (GLs) GL 99 , GL 100 , and amended GL 8J , authorizing certain transactions involving MOEX, NCC, NSD, or any entity in which one of these entities owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater… Read more