> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of

> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions Seems to be pretty clear that it would include non-government entities in sanctioned countries.