Technology companies must consider immediately suspending service to individuals and businesses in Russia. Every company should ask themselves today:
How will we protect our users in Russia and Ukraine?
How will we support our employees in Russia and Ukraine?
Will we continue providing services to users located in Russia?
If we continue providing service in Russia, should we make changes to our product? And how will we make continuing decisions on this topic?
How will we deal with attempts to evade sanctions from outside of Russia?
Sanctions now being implemented by the US, EU, and other partners are designed to create society-wide pressure on the Russian leadership. They can only be effective if there is strong participation by industry. Technology companies have the opportunity to either support the aims of the sanctions–and help hasten the end of the conflict for the benefit of both Russian and Ukrainian people–or to stand idle and risk providing tools that undermine sanctions and prolong the conflict.
As sanctions take effect, Russian users will likely move payments, communications, and other services to firms that are less tightly controlled or fall outside of the direct application of sanctions. This is especially true of cryptocurrencies and other new payment mechanisms with weak traceability (e.g., Monero) and little to no regulatory oversight. A flight of money to these services risks weakening the impact of the sanctions regime and prolonging the suffering of those affected by Russia’s invasion.
We recognize that the vast majority of people–both Russian and Ukrainian–don’t want war and that depriving them of key services can inflict real hardship. Our guidance is premised on the view that the quickest way to restore peace and order, and avoid continuing escalation, is to support the global sanctions regime, and that this support is consistent with the intent of the law.
Read our full guidance memo here.