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Treasury Clarifies ‘New Investment,’ Services Bans in Russia Sanctions

S&P Global Market Intelligence

The U.S. Treasury Department defined the ban on "new investment in the Russian Federation," an aspect of sanctions that had raised questions from lawyers, and clarified bans on various services.


Bans on services

The Treasury also issued guidance June 9 to clarify the bans related to certain accounting, trust and corporate formation services and management consulting services. For example, prohibited accounting services include tax preparation, but selling related software and providing educational services are generally allowed.

"In my view, those FAQs also are well thought-out and address specific use cases that are relevant to that sector," Anthony Rapa, a partner who leads the national security team at Blank Rome LLP, wrote in an email.

"Perhaps one lingering question is whether the general license for wind-down activities will be renewed July 7, but it is too early for OFAC to make any pronouncement on that in any event," Rapa added.

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"Treasury Clarifies ‘New Investment,’ Services Bans in Russia Sanctions," by Zoe Sagalow was published in S&P Global Market Intelligence on June 14, 2022.