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Client Alert 23 May. 2022
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On May 8, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Determination prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, and management consulting services to any person located in the Russian Federation. In tandem with that, OFAC issued a Determination imposing economic sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, or by the Secretary of State, to operate or to have operated in the accounting, trust and corporate formation, or management consulting sectors of the Russian economy.
OFAC also released new general licenses related to telecommunications. OFAC and the State Department have made new designations.
In a Determination pursuant to E.O. 14071, OFAC has specifically prohibited the “exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, or management consulting services to any person located in the Russian Federation.” The prohibition will take effect at 12:01 a.m. Eastern Daylight Time (EDT) on June 7, 2022.
FAQ 1034 and 1035 define the prohibited services as follows:
The prohibitions will not apply to the following entities:
This is OFAC’s first E.O. 14071 Determination. Curtis will monitor any future developments.
In conjunction with the E.O. 14071 Determination, OFAC issued two general licenses authorizing certain wind down transactions related to these services.
In a Determination pursuant to E.O. 14024, issued in parallel with the E.O. 14071 Determination, OFAC has determined that section 1(a)(i) of E.O. 14024 applies to “the accounting, trust and corporate formation services, and management consulting sectors of the Russian Federation economy.”
FAQ 1037 clarifies that a “sector determination pursuant to E.O. 14024 exposes persons that operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector. Only persons determined, pursuant to E.O. 14024, by the Secretary of the Treasury in consultation with the Secretary of State, or by the Secretary of State, in consultation with the Secretary of the Treasury, or their delegates, to operate or have operated in the above-identified sectors are subject to sanctions.”
Therefore, while the E.O. 14024 Determination will take effect immediately on May 8, 2022, it does not apply to any person in these sectors until there has been a designation. There has been no such designation to date specifically related to the abovementioned service sectors.
OFAC also updated and reissued General License 25A and issued General License 33:
Pursuant to E.O. 14024, OFAC has designated the following persons and entities that are “critical to Russia’s ability to wage war against Ukraine”:
The State Department has also designated the following entities pursuant to E.O. 14024 Section 1(a)(i) in the maritime sector:
Curtis will continue to monitor developments in this rapidly changing area.
National Security Law
Jason D. Wright
PARTNER, ECONOMIC SANCTIONS CHAIR, NATIONAL SECURITY LAW CHAIR
John Taishu Pitt
+1 212 696 6000
+1 202 452 7373
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