What OFAC’s New Cyber-Related Sanctions Regulations Mean for Companies

The U.S. government opened 2016 with new regulations to respond to and deter cyber attacks on it. On December 31, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control issued regulations requiring the blocking of any assets of, and prohibiting transactions with, perpetrators of malicious cyber-enabled activities. The regulations reflect the “Obama Administration’s recognition that cyber attacks and espionage are a real concern to the U.S. national security and economy,” Joseph Moreno, a Cadwalader partner and former federal prosecutor in the Counterterrorism Section of the DOJ’s National Security Division, told the Cybersecurity Law Report. He and other experts suggested steps companies can take to avoid running afoul of these new regulations and shared insights on what is to come. See also “Gibson Dunn Attorneys Discuss the Impact of Obama’s Executive Order Creating New Tools to Fight Cyber Attacks” (May 6, 2015).

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