[skissane]

It depends on the legal structure.

If they set up a subsidiary in Europe, they could be held liable for actions of European subsidiary.

If an independent org is stood up in Europe, with European directors, staff and funding, legally independent of US org, and the US org just provides advice/assistance to Europe org without ability to control it-legal liability for US org for Europe org’s decisions is less likely. Of course, ask a lawyer-but if you openly say “we are doing this to work around US sanctions” you could still be liable; if you say “this has nothing to do with sanctions this is about resilience of global digital infrastructure and European digital sovereignty” then under what legal theory is the US org liable?