On December 31, OFAC issued the Cyber-Related Sanctions Regulations, implementing President Obama’s April 2015 executive order that imposed sanctions on persons involved in malicious “cyber-enabled” activities.  The new regulations formally implement the executive order, but do not elaborate upon the order or provide detailed interpretive guidance.  Notably, OFAC has not made any designations under this sanctions regime to date, although designations could be forthcoming.

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