Yeah, that is my assumption. However, the process to get my account restored involved emailing [email protected], implying that I or PayPal was in violation of OFAC. I asked for clarification on whether this was a legal issue considering sanctions had recently been relaxed, but I never got an answer. The way this "non-bank" handles money often seems a bit disconcerting.

Sorry I've taken this a bit off topic, but hopefully this serves as a friendly reminder.