> the following persons are blocked...:
> (v) to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in, any of the following:
> (A) actions or policies that threaten the peace, security, stability, or territorial integrity of Belarus; ... (E) public corruption related to Belarus
> (vi) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any activity described in subsections (v)(A)–(E) of this section or any person whose property and interests in property are blocked pursuant to this order; or
> (vii) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, the Government of Belarus or any person whose property and interests in property are blocked pursuant to this order.
So, i'm no expert in sanctions, but it seems that anyone who made an app used by Belarusian KGB or other government organization could be sanctioned.
0: https://home.treasury.gov/system/files/126/20210809_belarus_...