Russia/Ukraine Crisis: U.S. Sanctions Escalation Continues

On May 8, 2022, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued broad restrictions against the provision of accounting, trust, and corporate formation, as well as management consulting services, to parties located in the Russian Federation. As a practical matter, the new restrictions will prohibit or deter U.S. persons from engaging in many corporate activities involving Russia, as the evolving U.S. regulatory framework increasingly resembles a broader embargo.

Accounting, Trust and Corporate Formation, and Management Consulting Services Prohibitions

Executive Order 14071, issued on April 8, 2022, prohibits "the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person," of any category of services subsequently identified by the U.S. government as impermissible.