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Practical Issues in Cyber-Related Sanctions

GIR: The Guide to Sanctions

In this chapter of Global Investigations Review: The Guide to Sanctions (Third Edition), authors Timothy O'Toole, Christopher Stagg, Caroline Watson, Manuel Levitt, Mary Mikhaeel, and Brian Fleming* provide an overview of the Cyber-Related Sanctions Program administered under the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) to target malicious cyber-related activities such as cyberespionage, cyber-intrusions on critical infrastructure and computer networks, and disinformation campaigns conducted from abroad. "OFAC's use of cyber-related sanctions authorities appears to be on the rise," the authors wrote, adding that, "OFAC enforcement of these sanctions authorities generally can be divided in two parts: the imposition of blocking or menu-based sanctions on individuals and entities for engaging in sanctionable activities…[and] the imposition of civil penalties for the violation of sanctions." 

*Former Miller & Chevalier attorney