By Maya Lester QC & Michael O’Kane

OFAC imposes restrictions on Russia quantum computing sector & issues 2 GLs

Alongside the additional Russia designations and export controls imposed by the US last week (previous post), OFAC issued a Determination Pursuant to Section 1(a)(i) of Executive Order (E.O.) 14024 and a Determination Pursuant to Section 1(a)(ii) of E.O. 14071, as well as 2 Russia-related General Licences (GLs). These are summarised below. OFAC Press Release, Notice, Notice & Notice.

Determination Pursuant to Section 1(a)(i) of E.O. 14024

This Determination identifies the quantum computing sector of the Russian economy pursuant to E.O. 14024 and allows for sanctions to be imposed on any person / entity determined to operate or have operated in this sector.

Determination Pursuant to Section 1(a)(ii) of E.O. 14071

This Determination prohibits the export, reexport, sale or supply (directly or indirectly) from the US or by a US person / entity, wherever located, of quantum computing services to any person / entity located in Russia.

OFAC has also published FAQs 1083 – 1086 and amended FAQs 1033, 1034, 1059, 1061 and 1062.

Russia-related GLs

  • GL 51 authorises until 15 October 2022 all transactions ordinarily incident and necessary to the wind down of any transaction involving Limited Liability Company Group of Companies Akvarius (Aquarius), or any entity in which Aquarius owns a 50% or greater interest.
  • GL 52 authorises US news reporting organisations and US journalists (including photojournalists) or broadcast or technical personnel to engage in certain transactions, where such transactions are ordinarily incident and necessary to journalistic activities or to the establishment or operation of a news bureau and are prohibited by E.O. 14024 or section (1)(a)(i) of E.O. 14071.

RussiaRussia United StatesUnited States

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Michael is Senior Partner at Peters & Peters LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters & Peters LLP...

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