In the June issue of ECM, I wrote an article describing the US, UK, and EU “professional services” sanctions that impose restrictions on services that can be provided to Russian parties. Shortly after the issue was published, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) implemented new sanctions on certain information technology and software services. OFAC’s new sanctions generally mirror those imposed by the EU, with a few differences.
While these new US sanctions ar...
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