InfoBytes Blog
OFAC amends cyber-related sanctions regulations
On September 2, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) announced that it is amending, and reissuing in their entirety, the Cyber-Related Sanctions Regulations. OFAC noted that this administrative action replaces regulations that were published in abbreviated form on December 31, 2015, with a more comprehensive set of regulations that includes additional interpretive and definitional guidance, general licenses, and other regulatory provisions that will provide further guidance to the public. As previously covered by InfoBytes, the regulations prohibited all transactions described in Executive Order (E.O.) 13694, including dealing in the property or interests in property, that come within the United States, of blocked persons. Among other things, under E.O. 13694, a party may be blocked if the U.S. government finds the party “to be responsible for or complicit in, or to have engaged in, directly or indirectly, cyber-enabled activities originating from, or directed by persons located, in whole or in substantial part, outside the U.S. that are 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” and that have one of the purposes or effects enumerated in the order. The sanctions became effective September 6.
Additionally, OFAC noted that “the publication of this final rule has triggered an automatic administrative update to a number of sanctions entries.” OFAC listed unique identifier numbers (UIDs) for the affected entries as part of the administrative update and provided FAQs to clarify UIDs.