Clifford Chance

OFAC Issues New Cyber-Related Sanctions Regulations

5 January 2016

To ring in the new year, the US Treasury Department's Office of Foreign Assets Control issued the Cyber-Related Sanctions Regulations, 31 CFR Part 578, on December 31, 2015. In its release of these implementing regulations, OFAC noted that they have been "published in abbreviated form for the purpose of providing immediate guidance to the public." OFAC explained that it "intends to supplement this part with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, including regarding 'cyber-enabled' activities, and additional general licenses and statements of licensing policy." Companies are well advised to consider appropriate steps to mitigate their risks arising under these new regulations.

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