OFAC FAQ #1193 · Russian Harmful Foreign Activities Sanctions
I am a U.S. company with a subsidiary organized and located in Russia. Can I provide the employees or contractors of my Russian subsidiary who are located in Russia with the services prohibited by the Information Technology (IT) and Software Services Determination under the exclusion "(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person?
OFAC's answer
Yes, as long as the services provided are within the employees’ or contractors’ scope of employment for or on behalf of the U.S. subsidiary company located in Russia. For additional information on the IT and Software Services Determination, see [FAQs 1184 - 1188](https://ofac.treasury.gov/faqs/search/1184+1185+1186+1187+1188), and [FAQ 1192](https://ofac.treasury.gov/faqs/1192).