I mean, theoretically not, but practically yes. Basically every bank has dollar reserves and as such get caught up in the sanctions screening process. Again, sanctions are most problematic for entities when used by the US, but the EU and other governments also do this, and if you want to transact in a governments currency, then you need to follow the sanctions laws (severe violations can lead to license revokation which basically kills your business).

Unless you have no connection to the fiat ecosystem, then you are gonna end up subject to these laws. And if you have no connection to the fiat ecosystem, you won't be a particularly useful service to most people or businesses.