Leagal questions regarding working with Russian developers (USA)

Question

I know no one can give me formal legal advise here but I have some questions about US sanctions on Russia. I run my own one person software consulting firm and was recently asked by a long time client (A US owned/operated company) to help out on a new project. The software development is being led by a group of Russian developers who have been hired/contracted to develop the code which is owned by my client. I am trying to understand if I should be concerned about US sanctions on Russia but it's hard to untangle the legalize. My understanding right now is that as long as I am not providing engineering services and building code that would be owned by a Russian company then it is ok? And it's perfectly legal for my clients to contract out Russian devs as long as the specific company is not sanctioned and there is no controlled tech changing hands?

mamonster · Accepted Answer

I've dealt with some related issues to this, but in the EU jurisdiction(but am familiar with US landscape).
1: You are not prohibited from working with Russian developers who currently reside in Russia. The biggest issue is figuring out a way for you to pay them, but that sounds like its being taken care of by the company.
2: You ARE prohibited from exporting consulting services to Russia, to either physical or legal persons, for "enterprise management software and design and manufacturing software": https://ofac.treasury.gov/faqs/added/2024-06-12#:~:text=1407...
3:Just contact OFAC. They are responsible for enforcement, and they have a hotline you can use.
https://ofac.treasury.gov/contact-ofac

eschneider · Answer

Assuming you don't decide that this is too much hassle (Even if you're not doing anything wrong, it sounds like your client would be. Do you really want to be part of that?) you need to talk to a lawyer who specializes in this sort of law.Seriously though, you don't need this hassle.

java-man · Answer

You'll be funding the russian war in Ukraine indirectly (with the taxes paid by these developers).