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OFAC Amends Cyber-Related Sanctions Regulations and Associated Lists

OFAC has amended and reissued the entirety of its Cyber-Related Sanctions Regulations. This administrative action replaces the regulations 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.

These more comprehensive regulatory guidelines encompass guidance and objectives from two executive orders:

  • Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-enabled Activities; and

  • Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities.

The Cyber-Related Sanctions Regulations were published in the Federal Register on Tuesday, September 6, 2022. The new set of regulations is more critical of suspected cyber criminals due to both the new licenses and the change in definitions for some of the previously ambiguous terms.

In addition, the publication of this final rule has triggered an automatic administrative update to a number of sanctions entries. The unique identifier numbers (UIDs) for the affected entries are listed throughout OFAC’s FAQ on UIDs.

Are you curious about the major points of this amendment? Are you still confused about some of the ambiguous language? Contact our office today.

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