As someone who has been trying to figure out just the OFAC sanctions and what entities they impact (and what those entities internet presence is), the situation is a mess. I assume at some point I'll have to repeat the thing with the EU etc. sanctions, hopefully they are 99% the same
Yes, it’s complicated. There are SDN entities that are fully blocked, non-SDN, various debt restrictions, restrictions on financial transactions only, sectoral sanctions (created after the Crimea invasion), guidance, general licenses, wind-down periods, etc. I think the EU ones and other countries’ are simpler. OFSI has an OFAC-style regime, but it’s also a bit simpler.
As someone who has been trying to figure out just the OFAC sanctions and what entities they impact (and what those entities internet presence is), the situation is a mess. I assume at some point I'll have to repeat the thing with the EU etc. sanctions, hopefully they are 99% the same
Yes, it’s complicated. There are SDN entities that are fully blocked, non-SDN, various debt restrictions, restrictions on financial transactions only, sectoral sanctions (created after the Crimea invasion), guidance, general licenses, wind-down periods, etc. I think the EU ones and other countries’ are simpler. OFSI has an OFAC-style regime, but it’s also a bit simpler.