New EU Sanctions FAQs for Russia Cover Advanced Tech Servicing Restrictions, More
The European Commission on Jan. 22 added several new FAQs to its sanctions guidance covering Russia-related service restrictions, including how those restrictions apply to advanced technology services such as AI, commercial space activities, tourism and travel, and more.
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New FAQ 38 outlines the types of AI-related services -- such as “access to models or to platforms for their training, fine-tuning and inference” -- that are prohibited. The EU said it bans the provision to the Russian government and Russian entities of both access to models and access to training platforms, and the FAQ lists how the EU defines those sets of activities. The EU said its AI model access restrictions, for example, prohibit a scenario where a provider hosts a pre-trained AI model and makes it available to a customer, “often through an Application Programming Interface.”
The restrictions cover Russian access to large language models for “text generation or analysis,” access to AI models for “image or video generation,” and access to specialized models for specific tasks like translation, voice transcription or software coding.
The restrictions also apply to the provision of computing infrastructure, software tools and frameworks that Russian customers may need to operate their own AI models. This specifically prohibits providing services to platforms that allow a customer to train a new AI model from scratch, fine-tune an existing model or run inference on their own model.
Also new, FAQ 39 covers the restrictions that apply to advanced computing services, including “access to graphic processing unit-accelerated computing” and quantum computing services. The EU said its sanctions are “meant to block” Russia’s access to EU “large-scale computational power that is essential to run highly complex tasks.” The ban specifically covers any services that allow for the renting of GPU-powered virtual machines through the cloud, the provision of “computer time-share” services on supercomputers, and “providing API-based access to GPU or HPC clusters for computational tasks.”
In addition, the EU said it restricts services that provide access to “quantum computers or quantum-emulating software,” including services that would allow users to “run algorithms for tasks far beyond the capability of classical computers, for instance advanced simulation, complex cryptography or large-scale optimisation problems.”
New FAQ 37 covers Russia-related restrictions over certain commercial space-based services, such as Earth observation or satellite navigation. EU companies are prohibited from selling, licensing or transmitting “optical, radar or hyperspectral satellite imagery”; providing “geospatial products” based on Earth-observation data; providing subscription-based access to commercial global navigation satellite system “augmentation signals or correction services”; offering “high-accuracy navigation or timing feeds to industrial or governmental users”; and more.
Other new FAQs starting on page 26 cover service restrictions related to tourism, travel, websites, diplomatic visits to Russia and more. The EU said it prohibits a range of Russia-related tourism and visa services, including tourist guide services, travel agency and tour operator services, visa facilitation services, the sale and brokering of plane or bus tickets, the provisions of websites that allow users to book hotels, transport or audio guides, and more.