OFAC FAQ #1065 · Russian Harmful Foreign Activities Sanctions

Do the prohibitions imposed by the determination made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” prohibit U.S. persons from serving as voting trustees on behalf of, or for shares of, persons located in the Russian Federation?

OFAC's answer

Yes, unless otherwise exempt or authorized by OFAC.

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