OFAC Issues Additional FAQs Relating to Russian Sanctions

OFAC issued new guidance clarifying certain aspects of Russian sanctions related to OFAC's May 8, 2022 determination on accounting, trust and corporate formation and management consulting services. The determination was made pursuant to Executive Order 14071 ("Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression").

The new FAQs concern, among others, the provision of accounting services (tax prep and filing); software or software services; educational services; executive search services and services provided to parent companies located in Russia. The new FAQs also address prohibitions on U.S. persons serving as voting trustees on behalf of, or for shares of, persons located in the Russian Federation; the application of the prohibitions on new and existing trusts; working as an employee of entities located in Russia; serving as directors of companies located in Russia, and providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation.