PDF: https://www.treasury.gov/resource-center/sanctions/Programs/...
PDF: https://www.treasury.gov/resource-center/sanctions/Programs/...
But, they don't want to say that. They want to blame it all on the government.
A lot of companies do this. Claim that their own business decisions about how to implement government regulations were forced by the government, when in truth it is their own commercial decisions around cost of compliance and risk appetite which were determinative, not the government regulation alone.
i.e. Do the same thing they are doing now, just be more open and honest about their reasons.
They officially apply to anyone who has ever, directly or indirectly, done anything on behalf of the government, or of those identified individuals and entities. So, if they made your presentation, it would be an inaccurate minimization of the plain language of the executive order.
Seems like not much of a stretch to consider all citizens controlled by the Gov.