OFAC FAQ #1066 · 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 the provision of educational services, such as online university courses, on the subjects of accounting, management consulting, or trust and corporate formation to persons located in the Russian Federation?
OFAC's answer
No, provided such services do not evade or avoid the prohibition on providing the underlying services to persons located in the Russian Federation.