QUESTION: Do ‘U.S. based’ social media companies violate sanctions if Foreign Terrorists Organizations (FTOs) agree to their company’s contractual agreement before establishing an account?
ANSWER: This is an issue governed by U.S. law, including laws that regulate interactions with designated entities. For example, persons subject to U.S. jurisdiction are prohibited from knowingly providing material support or resources to an entity that has been designated as Foreign Terrorist Organizations under section 219 of the Immigration and Nationality Act.
Additionally, it is illegal for persons subject to U.S. jurisdiction to engage in transactions with an entity that has been designated a Specially Designated Global Terrorist under Executive Order 13224.
We would refer you to the Department of Justice and the Department of the Treasury, respectively for any questions about how these are enforced in specific civil and criminal cases.
