E.O issued by US President Obama, dated April 1, 2015, named “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities.” The E.O states that the increasing prevalence and severity of malicious cyber-enabled activities originating from, or directed by persons located, in whole or in substantial part, outside the US constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the US. The President declared a national emergency to deal with this threat, and ordered several actions including that all property and interests in property that are in the US, that hereafter come within the US, or that are or hereafter come within the possession or control of any US person of persons that are detailed in the E.O are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in. On December 31, 2015, OFAC inaugurated ‘Cyber-Related Sanctions Regulations’, 31 C.F.R. Part 578, which implemented E.O. 13694. OFAC also issued a series of Frequently Asked Questions (“FAQs”) to provide guidance on the precise scope of E.O. 13694.

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