I think Relic don't often read our Threads on this page, so I made a post in their forum.
https://community.companyofheroes.com/discussion/243043/question-about-terms-and-conditions-of-tournament#latest
After 12 min i got a response. Not from Relic, but from a mod, who locked down my thread.
"First: I do want to make clear that I do not speak for Relic or SEGA for this paragraph. According to my understanding of the political situation, The Russian Federation is not a sanction country. There are indeed sanctions in place due to the Crimea incident, but according to the most up-to-date list that you provided, the sanctions are against specially designated nationals of of Ukraine or Russia, but not a country sanction. Therefore, I do not see any infractions of the tournaments T&C, and no disqualifications are required.
[Moderator Input] Personally, I do understand that you wish to discuss the T&Cs of this tournament. However, since you clearly specify in the opening post that this thread is targeted towards Relic whilst demanding a response from Relic staff, I am closing this thread. Threads should encourage discussion between fans rather than require participation from Relic or SEGA staff. I do encourage you to get an answer to your question, therefore I highly recommend to contact Relic or SEGA directly to discuss what you believe are legal issues of this tournament. I do strongly believe that you will get better results than discussing legal issues in a fan oriented discussion forum.
HTH"