OFAC implements US cyber-sanctions

OFAC has issued regulations to implement sanctions introduced by President Obama in April 2015 under Executive Order 13694 that target people and entities responsible for malicious cyber-activities (see previous blog).  In its notice, the US Treasury states that it intends to supplement the new regulations with a more comprehensive set in the future, which may include additional guidance, general licences, and statements of licensing policy.

The activity targeted by the Executive Order includes:

  • harming or significantly compromising the provision of services by entities in a critical infrastructure sector;
  • significantly disrupting the availability of a computer or network of computers, including through a distributed denial-of-service attack;
  • misappropriating funds or economic resources, trade secrets, personal identifiers, or financial information for commercial or competitive advantage or private financial gain;
  • knowingly receiving or using trade secrets that were stolen by cyber-enabled means for commercial or competitive advantage or private financial gain;
  • attempting, assisting, or providing material support for any of the harms listed above; and
  • being owned or controlled by, or acting on behalf of, any person whose property or interests are blocked under the order.
This entry was posted in USA by Maya Lester QC. Bookmark the permalink.

About Maya Lester QC

Maya Lester QC has a wide ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. As the most recent (2016) Chambers & Partners directory put it, she "owns the world of sanctions". She spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She represents and advises hundreds of companies and individuals before the European and English courts and has acted in most of the leading cases, including Kadi, Tay Za, Central Bank of Iran, NITC and IRISL.

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