The Advisory implicates the International Economic Powers Act (IEPA) and the Trading With the Enemy Act (TWEA), both of which explicitly prohibit private entities from engaging in trading activities with individuals or enterprises listed on OFAC's Specially Designated Nationals and Blocked Person's List (the Sanctions List). The Advisory states that even individuals who "did not know or have reason to know" that they were dealing with a sanctioned entity may still be sanctioned. The Advisory, nonetheless, still tacitly recognizes that making ransomware payments may be necessary.