Department of Commerce may make exceptions.

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The U.S. Treasury Department issued a disclaimer that the United States supports the free flow of information and communications around the world, and these actions are not intended to undermine civil society and civilian telecommunications. "Despite the new prohibitions, OFAC maintains authorizations for certain telecommunications, internet, and humanitarian operations under General Licenses 6D and 25D, which mitigate the impact on Russian civil society uganda whatsapp resource and protect public access to information and communications technology.

OFAC's General License 6D applies to transactions involving agricultural commodities, drugs, medical devices, spare parts and components or software updates, the coronavirus disease 2019 (COVID-19) pandemic, or clinical trials in Russia. OFAC's General License 25D is entitled "Authorization of Transactions [in the Russian Federation] Related to Telecommunications and Certain Types of Internet Communications."

The new sanctions should not have a major impact on the Russian IT industry and its clients. No one in Russia has used the services of American IT systems and infrastructure design companies or their IT consulting for more than two years.

As for the ban on the provision of IT support services and cloud services related to software for enterprise management, design and production, since mid-2022, industrial competence centers (ICC) have been operating in the Russian Federation, the purpose of which is to develop domestic digital products to replace specialized software, which until 2022 was almost entirely imported.

Some Russian companies in various sectors of the economy continue to use foreign software products, for the acquisition and licensing of which they spent large sums of money – but they do this in a protected (isolated) environment and plan to switch to domestic products as the foreign software depreciates.