https://home.treasury.gov/policy-issues/financial-sanctions/...
118. I have a client that is in Iran to visit a relative. Do I need to restrict the account?
A: No. As long as you are satisfied that the client is not ordinarily resident in Iran, then the account does not need to be restricted. See FAQ 37.
Source:
https://twitter.com/Hamed/status/1346433510786138114/photo/1My thoughts are my own. I do not represent anyone other than myself.
On the other hand, a sanctions violation could be a $65,000 fine (Trading with the Enemy Act) or $250,000 (International Emergency Economic Powers Act) for each offense. (I leave aside the million-dollar narcotics-kingpin act). On top of this we also see the risk of criminal prosecution.
In what world is it reasonable to expect anyone to take this chance?
Sanctions, compliance, etc. is a messy ordeal to manage (both technically and operationally), and the ways laws are written with so many intricacies and dependencies doesn't make it easier.
Because only 1 instance of violation could lead to fines equivalent to a person's salary, often the systems are made to be overly sensitive and less investigative to figure out whether a 'hit' is actually a false-positive because that also takes time/money and still carries potential risk.
Advancing developer freedom: GitHub is fully available in Iran
https://news.ycombinator.com/item?id=25648585Github cannot be expected to reliably differentiate between the coworker who just checked the status of a PR on a webapp versus the employee who opened a crucial piece of encryption code to leak it to the Iranian military or whatever.