The key paragraph, to which I direct your attention, is located at the bottom of the press release, and may contribute to the calculations that Cogent and other companies, with the advice of their lawyers, not some idiot without a law degree like me, advising them.

There are others on this list who do have access to a lawyer who could advise them to what the ramifications of doing business with companies in Russia which are primarily owned, directly or indirectly through shell companies, by a select chosen few, many of whom are listed in the body of this cited press release. That is what an Oligarchy is, a country owned and operated by a select few.

"In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person."

Personally, I think providing an internet connection would be a service, whether paid for or no, and that would be prohibited, without first getting a specific waiver or license to do so. But, I am just a lay person, and would seek the advice of a lawyer before I did anything that might violate these orders.


On 3/7/22 07:14, J. Hellenthal via NANOG wrote:
Yet another trash understanding from Jeff.

Give it a break dude!

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JeffP