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U.S. Authorizes Cyber Sanctions, Recommends Tech Companies Adopt Compliance Programs
6 April 2015
View Client Update
On April 1, 2015, President Obama issued a new Executive Order authorizing sanctions against persons that engage in certain significant and malicious cyber-enabled activities that threaten the United States.
Concurrently, the Treasury Department’s Office of Foreign Assets Control has called on “firms that facilitate or engage in online commerce” and other technology companies to have in place “a tailored, risk-based compliance program, which may include sanctions list screening or other appropriate measures.”
In light of this guidance, it may be prudent for technology and e-commerce companies to review their sanctions-related risks and enhance their compliance programs to address this new sanctions framework.
Cybersecurity & Data Privacy
International Economic Sanctions & OFAC Compliance
Satish M. Kini
David A. O'Neil
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