Businesses in US-embargoed jurisdictions, including Iran, Cuba, Crimea, and Syria, market their ad placement services with digital advertising giants such as Google and Twitter. In some instances, the firms appeared to have provided services on behalf of sanctioned companies.

The US Department of the Treasury notes that online commerce firms “are responsible for ensuring that they do not engage in unauthorized transactions or dealings with persons” operating “in jurisdictions targeted by comprehensive sanctions programs,” such as Iran, Cuba, Crimea, and Syria. 

Google’s advertising policy prohibits “ad campaigns that are run on behalf of businesses that are located in embargoed countries or regions, even if the account owner is not located in an embargoed country or region.” 

Twitter enforces a similar policy that prohibits “advertisements targeted to, and advertiser accounts from countries subject to U.S. trade sanctions and other U.S. export control laws.”

Facebook, for its part, mandates that “if you are located in a country that is subject to embargo under the laws of the United States (or under similar laws applicable to you) you may not engage in commercial activities on Facebook Products unless authorized by applicable laws.”