The scope of prohibited ICTS Transactions include transactions between U.S. persons and a “ person owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary.” The definition of this category of persons includes the following: Any person, wherever located, who acts as an agent, representative, employee, or any other capacity at the order, request, direction, or control of a foreign adversary; A person whose activities are directly or indirectly supervised, directed, controlled, financed or subsidized in whole or in majority part by a foreign adversary; Any person wherever located who is a citizen or resident of a nation-state controlled by a foreign adversary;