On 22 May, the US Treasury Department’s Office of Foreign Asset Control (“OFAC”) published General License No. 9 in respect of Executive Order No. 13,685, which imposed a trade embargo on Crimea. The new licence allows the provision to Crimea of most software and services related to personal communication over the Internet, but only if the software or services are widely available to the public at no cost to the user.
This includes, for example, social networking, blogging, email and instant messaging services and software. However, providing web hosting services for commercial endeavours and domain-name registration services to Crimea remains forbidden.
The licence also does not authorise the exportation or reexportation of services or software when the exporter or reexporter has knowledge or reason to know that such services or software are intended for any person whose property and interests in property are blocked. OFAC also has issued a new Frequently Asked Question explaining the scope of this last restriction.