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What is it based on? I'm playing as a neutral (yet belligerent) Italy, but I'm subject to an embargo by the US. Is there any specific reason (high belligerence) or did I just not see it from the start?
AI settings files are loaded on country creation and via AI events (at any time). The AI events use triggers and ideally try to react to the current game situation. You can check USA AI events and files and see what the conditions for the embargo are.