You’re right. I thought these would apply internationally but it seems like it’s only if one of the party is a US citizen: https://www.jdsupra.com/post/contentV

You’re right. I thought these would apply internationally but it seems like it’s only if one of the party is a US citizen: https://www.jdsupra.com/post/contentViewerEmbed.aspx?fid=f66d4fe6-e3b4-4be0-91f7-a065cfadeee8 https://www.jdsupra.com/post/contentViewerEmbed.aspx?fid=f66... At least for ofac