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<option value="1651">Appeal an OFAC SDN Designation or other listing</option>
<option value="1591">Assessing OFAC Name Matches</option>
<option value="1501">Basic Information on OFAC and Sanctions</option>
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2. Office of Foreign Assets Control - Sanctions Programs and Information
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FINANCIAL SANCTIONS
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Companies SanctionsCompliance for Internet, Web Based Activities, and Personal
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SanctionsCross-Programmatic Compliance Services GuidanceCuba
SanctionsCyber-related SanctionsEntities Owned by Blocked Persons (50%
Rule)Ethiopia-Related SanctionsFiling Reports with OFACGlobal Magnitsky
SanctionsHong Kong-related SanctionsHow to Receive Notifications About OFAC
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Information on a Credit ReportOFAC LicensesQuestions on Virtual CurrencyRussian
Harmful Foreign Activities SanctionsSee OFAC's Complete List of Sanctions
ProgramsSomalia SanctionsSpecially Designated Nationals (SDNs) and the SDN
ListStarting an OFAC Compliance ProgramSudan, Darfur, and South Sudan-related
SanctionsSyria SanctionsUkraine-/Russia-related SanctionsVenezuela SanctionsWeak
Aliases
Russian Harmful Foreign Activities Sanctions
1068. FOR THE PURPOSES OF THE DETERMINATION MADE PURSUANT TO EXECUTIVE ORDER
(E.O.) 14071 ON MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN ACCOUNTING, TRUST
AND CORPORATE FORMATION, AND MANAGEMENT CONSULTING SERVICES” (“THE
DETERMINATION”), DO ACCOUNTING SERVICES INCLUDE TAX PREPARATION AND FILING?
Yes. U.S. persons, wherever located, are prohibited from exporting,
reexporting, selling, or supplying, directly or indirectly, accounting services,
which would include tax preparation and filing services, to any person located
in the Russian Federation, unless otherwise exempt or authorized by OFAC.
Please see FAQ 1059 for more information. Please note the determination
excludes the provision by a U.S. person of any service to an entity located in
the Russian Federation that is owned or controlled, directly or indirectly, by a
United States person, and any service in connection with the wind down or
divestiture of an entity located in the Russian Federation that is not owned or
controlled, directly or indirectly, by a Russian person.
As noted in FAQ 1067, this determination does not prohibit the export, reexport,
sale, or supply, directly or indirectly, of tax preparation-related software to
the Russian Federation, as distinct from tax preparation and filing services.
Please see FAQ 1067 for more information.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1067. DO THE PROHIBITIONS IMPOSED BY THE DETERMINATION MADE PURSUANT TO
EXECUTIVE ORDER (E.O.) 14071 ON MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN
ACCOUNTING, TRUST AND CORPORATE FORMATION, AND MANAGEMENT CONSULTING SERVICES”
(“THE DETERMINATION”), PROHIBIT U.S. PERSONS FROM PROVIDING SOFTWARE RELATED TO
ACCOUNTING, MANAGEMENT CONSULTING, OR TRUST AND CORPORATE FORMATION TO PERSONS
LOCATED IN THE RUSSIAN FEDERATION?
The determination does not prohibit U.S. persons from exporting, reexporting,
selling, or supplying, directly or indirectly, software to the Russian
Federation, nor does the determination prohibit U.S. persons from providing
services associated with the export of such software, such as software design
and engineering, provided that such associated services do not fall within the
categories of management consulting, accounting, or trust and corporate
formation.
For example, the following scenario describes activities that would not be
prohibited under the determination:
* A U.S. software company signs a contract with a company located in the
Russian Federation (“Russian company”) for design, engineering, licensing,
and delivery of software that the Russian company uses to perform its
internal accounting. As part of the contract, the U.S. company provides
continuing updates and technical support services related to the software
(setting up new users, troubleshooting errors, etc.).
The following scenarios illustrate activities that would be prohibited under the
determination:
* A U.S. management consulting company signs a contract with a Russian company
to assist the Russian company in selecting a new enterprise application
software. This contract includes assessing the needs of the Russian company,
providing a list of possible software choices to the company, and providing
continuing advisory services on the implementation and use of the software to
optimize the Russian company’s profits.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1066. DO THE PROHIBITIONS IMPOSED BY THE DETERMINATION MADE PURSUANT TO
EXECUTIVE ORDER (E.O.) 14071 ON MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN
ACCOUNTING, TRUST AND CORPORATE FORMATION, AND MANAGEMENT CONSULTING SERVICES,”
PROHIBIT THE PROVISION OF EDUCATIONAL SERVICES, SUCH AS ONLINE UNIVERSITY
COURSES, ON THE SUBJECTS OF ACCOUNTING, MANAGEMENT CONSULTING, OR TRUST AND
CORPORATE FORMATION TO PERSONS LOCATED IN THE RUSSIAN FEDERATION?
No, provided such services do not evade or avoid the prohibition on providing
the underlying services to persons located in the Russian Federation.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1065. DO THE PROHIBITIONS IMPOSED BY THE DETERMINATION MADE PURSUANT TO
EXECUTIVE ORDER (E.O.) 14071 ON MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN
ACCOUNTING, TRUST AND CORPORATE FORMATION, AND MANAGEMENT CONSULTING SERVICES,”
PROHIBIT U.S. PERSONS FROM SERVING AS VOTING TRUSTEES ON BEHALF OF, OR FOR
SHARES OF, PERSONS LOCATED IN THE RUSSIAN FEDERATION?
Yes, unless otherwise exempt or authorized by OFAC.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1064. ARE EXECUTIVE SEARCH AND VETTING SERVICES INCLUDED IN THE PROHIBITION ON
MANAGEMENT CONSULTING SERVICES IMPOSED BY THE DETERMINATION MADE PURSUANT TO
EXECUTIVE ORDER (E.O.) 14071 ON MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN
ACCOUNTING, TRUST AND CORPORATE FORMATION, AND MANAGEMENT CONSULTING SERVICES”?
Yes. For the purposes of this determination, OFAC interprets management
consulting services to include services related to strategic business advice;
organizational and systems planning, evaluation, and selection; development or
evaluation of marketing programs or implementation; mergers, acquisitions, and
organizational structure; staff augmentation and human resources policies and
practices; and brand management. Please see FAQ 1034 for more information.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1063. DO THE PROHIBITIONS IMPOSED BY THE DETERMINATION MADE PURSUANT TO
EXECUTIVE ORDER (E.O.) 14071 ON MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN
ACCOUNTING, TRUST AND CORPORATE FORMATION, AND MANAGEMENT CONSULTING SERVICES”
(“THE DETERMINATION”), APPLY ONLY WITH RESPECT TO THE FORMATION OF NEW TRUSTS
AND COMPANIES OR DO THE PROHIBITIONS ALSO APPLY WITH RESPECT TO EXISTING TRUSTS
AND COMPANIES?
The prohibitions imposed by the determination do not distinguish between new and
existing trusts and companies. Under the determination, U.S. persons are
prohibited from providing trust and corporate formation services to persons
located in the Russian Federation, regardless of whether the services are
performed as part of the formation of a new trust or company, or as part of the
administration or maintenance of an existing trust or company. Please see FAQ
1034 for more information.
In addition, please note that the determination excludes from the scope of the
aforementioned services: (1) any service to an entity located in the Russian
Federation that is owned or controlled, directly or indirectly, by a United
States person; and (2) any service in connection with the wind down or
divestiture of an entity located in the Russian Federation that is not owned or
controlled, directly or indirectly, by a Russian person.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1062. DO THE PROHIBITIONS IMPOSED BY THE DETERMINATION MADE PURSUANT TO
EXECUTIVE ORDER (E.O.) 14071 ON MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN
ACCOUNTING, TRUST AND CORPORATE FORMATION, AND MANAGEMENT CONSULTING SERVICES,”
APPLY TO SERVICES PROVIDED TO A PARENT COMPANY LOCATED IN THE RUSSIAN FEDERATION
BY A U.S. SUBSIDIARY?
Yes. The prohibitions apply to services provided to a company located in the
Russian Federation (the “Russian company”) by any U.S. person, including the
Russian company’s U.S. subsidiary.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1061. DOES THE DETERMINATION MADE PURSUANT TO EXECUTIVE ORDER (E.O.) 14071 ON
MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN ACCOUNTING, TRUST AND CORPORATE
FORMATION, AND MANAGEMENT CONSULTING SERVICES” (“THE DETERMINATION”), PROHIBIT
U.S. PERSONS FROM WORKING AS EMPLOYEES OF ENTITIES LOCATED IN THE RUSSIAN
FEDERATION?
Not necessarily. Under the determination, U.S. persons are prohibited from
exporting, reexporting, selling, or supplying, directly or indirectly,
management consulting, trust and corporate formation services, and accounting
services to persons located in the Russian Federation. Thus, U.S. persons are
prohibited from providing these services to companies located in the Russian
Federation (“Russian companies”) in their capacity as employees. However, the
determination does not prohibit U.S. persons from providing other services not
covered by this determination as part of their employment by Russian companies.
In addition, please note that the determination excludes from the scope of the
aforementioned services: (1) any service to an entity located in the Russian
Federation that is owned or controlled, directly or indirectly, by a United
States person; and (2) any service in connection with the wind down or
divestiture of an entity located in the Russian Federation that is not owned or
controlled, directly or indirectly, by a Russian person.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1060. DOES THE DETERMINATION MADE PURSUANT TO EXECUTIVE ORDER (E.O.) 14071 ON
MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN ACCOUNTING, TRUST AND CORPORATE
FORMATION, AND MANAGEMENT CONSULTING SERVICES” (“THE DETERMINATION”), PROHIBIT
U.S. PERSONS FROM SERVING AS DIRECTORS OF COMPANIES LOCATED IN THE RUSSIAN
FEDERATION?
Under the determination, U.S. persons are prohibited from exporting,
reexporting, selling, or supplying, directly or indirectly, trust and corporate
formation services to persons located in the Russian Federation. This
prohibition on trust and corporate formation services does not, in and of
itself, prohibit U.S. persons from serving on the board of directors of a
company located in the Russian Federation.
However, this determination would prohibit U.S. persons from providing nominee
officer or director services in which a U.S. person is contracted to serve as a
nominee officer, director, shareholder, or signatory of a legal person on behalf
of a person located in the Russian Federation.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1059. DOES THE DETERMINATION MADE PURSUANT TO EXECUTIVE ORDER (E.O.) 14071 ON
MAY 8, 2022, “PROHIBITIONS RELATED TO CERTAIN ACCOUNTING, TRUST AND CORPORATE
FORMATION, AND MANAGEMENT CONSULTING SERVICES” (“THE DETERMINATION”), PROHIBIT
U.S. PERSONS FROM PROVIDING SERVICES TO PERSONS LOCATED OUTSIDE OF THE RUSSIAN
FEDERATION THAT ARE OWNED OR CONTROLLED BY PERSONS LOCATED IN THE RUSSIAN
FEDERATION?
No, provided that the provision of services is not an indirect export to a
person located in the Russian Federation. For the purposes of this
determination, OFAC interprets the “indirect” provision of the prohibited
services to include when the benefit of the services is ultimately received by a
“person located in the Russian Federation.”
In contrast, OFAC would not consider to be prohibited the provision of services
to a non-Russian company that has a physical presence and operations outside of
the Russian Federation, including such a company owned or controlled by persons
located in the Russian Federation, provided that the services will not be
further exported or reexported to persons located in the Russian Federation.
For example, the following scenarios describe services that would be prohibited
under the determination:
* A U.S. corporate service provider administers a trust established under the
laws of a U.S. state, where the trust exists predominantly to hold, sell, or
purchase assets on behalf of a settlor, trustor, or beneficiary who is an
individual ordinarily resident in Russia.
* A U.S. corporate service provider registers a limited liability company in a
third country on behalf of an individual ordinarily resident in Russia for
the purpose of holding real estate assets, and this company has no other
physical presence or operations in the third country.
The following scenarios illustrate services to a non-Russian subsidiary of a
Russian person that would not be prohibited under the determination:
* A U.S. accounting firm provides tax advisory and preparation services to the
U.S. subsidiary of a Russian company. This U.S. subsidiary has an office and
employees in the United States and conducts business in the United States,
and the services will not be exported or reexported to the Russian parent
company.
* A U.S. management consulting firm provides strategic business advice to the
subsidiary of a Russian company located in a third country. This subsidiary
has an office and employees in the third country and conducts business in
this third country, and the services will not be reexported to the Russian
parent company.
Released on 06/09/2022
Russian Harmful Foreign Activities Sanctions
1058. FOR THE PURPOSES OF SECTION 1(A)(II) OF EXECUTIVE ORDER (E.O.) 14071, WHAT
IS MEANT BY THE TERM “PERSON LOCATED IN THE RUSSIAN FEDERATION”?
For the purposes of section 1(a)(ii) of E.O. 14071, OFAC interprets “person
located in the Russian Federation” to include persons in the Russian Federation,
individuals ordinarily resident in the Russian Federation, and entities
incorporated or organized under the laws of the Russian Federation or any
jurisdiction within the Russian Federation.
Please note that section 1(a)(ii) of E.O. 14071 prohibits the direct or indirect
exportation, reexportation, sale, or supply from the United States, or by a
United States person, wherever located, of such services determined pursuant to
E.O. 14071. For the purposes of E.O. 14071, OFAC interprets the “indirect”
provision of such services to include when the benefit of the services is
ultimately received by a “person located in the Russian Federation.” Please see
FAQ 1059 for more information.
Released on 06/09/2022
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