As of December 28th, 2009, ASPnix cannot conduct business with Sudan, Syria, Cuba, North Korea, Iran (a.k.a. Persia), or Libya due to United States Treasury embargo restrictions. These prohibitions are enforced by the Office of Foreign Assets Control (OFAC) under multiple sanctions programs.
The core list above is taken directly from the referenced regulations in effect at that time. All US-based companies must screen for and reject transactions with these jurisdictions. Providing hosting services, support, or related billing would constitute a violation. The detailed references and penalty structures for each country are listed below.
#Understanding OFAC Embargo Restrictions
OFAC administers and enforces economic sanctions that implement US foreign policy and national security goals. For a hosting provider, this requires controls at account creation, payment processing, and ongoing service delivery to ensure no prohibited persons or entities receive access. The referenced main program page is http://www.ustreas.gov/offices/enforcement/ofac/programs/. Sanctions lists are not static; however the information here reflects the documented status as of the date shown in the original reference.
#Country-Specific Restrictions and Penalties
#Sudan
Reference: http://www.treasury.gov/resource-center/sanctions/Programs/pages/sudan.aspx PENALTIES: Criminal fines for violating the Regulations range, upon conviction, up to $1,000,000; individuals may also face imprisonment of up to 20 years. In addition, civil penalties of up to $250,000 or twice the amount of the underlying transaction may be imposed administratively for each violation. These measures apply to any form of trade or service provision.
#Syria
Reference: http://www.treasury.gov/resource-center/sanctions/Programs/pages/syria.aspx PENALTIES: Criminal penalties for violating the sanctions range up to 10 years in prison, $500,000 in corporate fines and $250,000 in individual fines. In addition, civil penalties of up to $11,000 per violation may be imposed administratively. Web hosting and related technical services fall under these trade prohibitions.
#Cuba
Reference: http://www.treasury.gov/resource-center/sanctions/Programs/pages/cuba.aspx PENALTIES: Criminal penalties for violating the sanctions range up to 10 years in prison, $1,000,000 in corporate fines, and $250,000 in individual fines. Civil penalties up to $55,000 per violation may also be imposed. Comprehensive sanctions prohibit most forms of commerce with Cuban entities.
#North Korea
Reference: http://www.treasury.gov/resource-center/sanctions/Programs/pages/nkorea.aspx PENALTIES: Criminal fines for violating the E.O. range, upon conviction, up to $1,000,000; individuals may also face imprisonment up to 20 years. In addition, civil penalties of up to $250,000 or twice the amount of the underlying transaction may be imposed administratively for each violation.
#Iran (a.k.a. Persia)
Reference: http://www.treasury.gov/resource-center/sanctions/Programs/pages/iran.aspx PENALTIES: Criminal penalties for violations of the Iranian Transactions Regulations may result in a fine up to $1,000,000, and natural persons may be imprisoned for up to 20 years. Civil penalties, which are not to exceed the greater of $250,000 or an amount that is twice the amount of the transaction that is the basis of the violation with respect to which the penalty is imposed may also be imposed administratively.
#Libya
Reference: http://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20110225.aspx
#Compliance Considerations
The listed penalties demonstrate the gravity of compliance. Criminal cases can result in both fines and imprisonment; civil penalties are assessed administratively and can accumulate rapidly across multiple violations. Hosting companies maintain internal screening processes to reject orders originating from or controlled by these jurisdictions. Common pitfalls include incomplete due diligence on beneficial ownership or attempts to route services through third countries.
#Practical Takeaway
Verify any prospective customer location against the current OFAC lists before proceeding with account requests. The data here is as of December 2009; always cross-check the official Treasury resources for updates. This approach prevents legal exposure and keeps service delivery focused on eligible customers. For account-related questions outside embargoed regions, standard signup and verification steps apply.
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