Executive Order (E.O.) 13694, as amended on December 29, 2016, focuses on specific harms caused by significant malicious cyber-enabled activities, and directs the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, to impose sanctions on those persons… Read more
As with many of the sanctions programs that Treasury administers, U.S. persons (and persons otherwise subject to OFAC jurisdiction) must ensure that they are not engaging in trade or other transactions with persons named on OFAC’s SDN List pursuant to E.O. 13694, as amended, or any entity owned… Read more
No. This authority does not target American whistleblower activity or constitutionally protected activity. The E.O. defines misappropriation to be the “taking or obtaining by improper means, without permission or consent, or under false pretenses.” Importantly, to be eligible for sanctions under… Read more
We anticipate that regulations to be promulgated will define “cyber-enabled” activities to include any act that is primarily accomplished through or facilitated by computers or other electronic devices. For purposes of E.O. 13694 , malicious cyber-enabled activities include deliberate activities… Read more
The measures in this order are directed against significant malicious cyber-enabled activities that have the purpose or effect of causing specific enumerated harms, and are not designed to prevent or interfere with legitimate cyber-enabled academic, business, or non-profit activities. The U.S.… Read more
The measures in this order are designed to address the threat posed by individuals and entities engaged in significant malicious cyber-enabled activities that have the purpose or effect of causing specific enumerated harms. These measures are not designed to prevent or interfere with legitimate… Read more
No. These sanctions are designed to target those actors whose malicious cyber-enabled conduct is reasonably likely to result in, or have materially contributed to, a significant threat to the national security, foreign policy, or economic health or financial stability of the United States. These… Read more
The United States’ whole-of-government strategy to combat cyber threats draws from a broad range of tools and authorities to respond to the growing and evolving threat posed by malicious cyber actors. Similar to our approach to global threats from terrorists, narcotics traffickers, and… Read more
GL 1C authorizes transactions with the Federal Security Service (a.k.a. Federalnaya Sluzhba Bezopasnosti) (a.k.a. FSB) that are ordinarily incident and necessary to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation, distribution, or… Read more
GL 1C only authorizes certain transactions and activities with the Federal Security Service acting in its administrative and law enforcement capacities. The GL was issued in order to ensure that U.S. persons engaging in certain business activities in Russia that are not otherwise prohibited are not… Read more