Yes. In general, any transaction or dealing by a U.S. person in any property or interests in property of persons designated as SDGTs under or otherwise blocked pursuant to E.O. 13224 is prohibited. Such property includes artwork and other information and information materials. Certain exemptions available under the International Emergency Economic Powers Act (IEEPA) relating to personal communications, humanitarian donations, information or informational materials, and travel do not apply to transactions with SDGTs or persons otherwise blocked pursuant to E.O. 13224.
For purposes of these prohibitions, U.S. persons include all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, and all U.S.-incorporated entities and their foreign branches. U.S. persons who engage in prohibited transactions with SDGTs or with persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties.
Non-U.S. persons who engage in prohibited transactions or dealings subject to U.S. jurisdiction with SDGTs or with persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT.