Positions at a glance
Supporters
The categories of restricted services have been progressively defined through Treasury determinations. Early determinations covered accounting, trust and corporate formation, and management consulting services (May 8, 2022), followed by quantum computing services (September 15, 2022), and later architecture and engineering services (May 19, 2023). On June 12, 2024, Treasury issued a determination expanding restrictions to cover IT consultancy, IT design and support, and certain cloud-based services for enterprise management and design/manufacturing software, effective September 12, 2024.
Opponents
EO 14071 works alongside EO 14066 (energy import ban) and EO 14068 (luxury goods and import bans) to form the post-invasion U.S. sanctions architecture against Russia. OFAC has issued numerous general licenses under EO 14071 to authorize wind-down activity, humanitarian transactions, telecommunications, and journalism. Violations carry civil penalties under the International Emergency Economic Powers Act (IEEPA) and potential criminal liability.
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In June 2024, the U.S. Treasury invoked EO 14071 to prohibit U.S. providers from supplying IT consultancy and cloud-based design software to persons in Russia, effective September 12, 2024.
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