On September 12, 2024, the U.S. Office of Foreign Assets Control issued new Frequently Asked Question 1192 and updated FAQ 1033 in connection with Russian Harmful Foreign Activities Sanctions. FAQ 1192 provides an overview of exclusions under 3(i) and 3(ii) related to the Export Administration Regulations with respect to the IT and Software Services Determination proposed by the Department of Commerce – prohibitions that went into effect on September 16, 2024.
OFAC also amended FAQ 1033 that addresses actions taken by the Director of OFAC, in consultation with the Department of State, on May 8, 2022 to prohibit certain accounting, trust and corporate formation, and management consulting services to persons located in Russia. The FAQ was updated to reflect prohibitions issued by the Treasury Department on June 12, 2024 that restrict certain IT and cloud-based services, which took effect on September 12, 2024.