> Let's Encrypt certificates continue to be available in both Iran and Russia, just not for the Iranian and Russian governments.

According to https://news.ycombinator.com/item?id=48457280 it affects all people ordinarily resident in those territories, not just their governments:

> You are not a person or entity that is:

> (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions;

> [other 'or' conditions]

you should update the documents to reflect this stance.

"You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; "

this says nothing (edit: specific) about government (edit: only), and is applicable to normal people in those areas.