Sanctions Profile: Cyber-Attacks

At a glance

The EU adopted Council Regulation (EU) 2019/796 and Council Decision (CFSP) 2019/797 in May 2019 to establish a new sanctions regime to deter and respond to malicious cyber activities on EU member states, third states and international organisations.

The UK adopted The Cyber (Sanctions) (EU Exit) Regulations 2020 in January 2021 to further the prevention of cyber activity that undermines the integrity, prosperity or security of the UK, causes economic loss, undermines the effective functioning of international organisations or NGOs, or affects a significant number of persons in an indiscriminate manner.

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News

Australia passes law providing for thematic sanctions regimes

Today (2 December 2021), the Australian Parliament passed the Autonomous Sanctions Amendment (Magnitsky-style and Other Thematic Sanctions) Bill 2021 which amends the Autonomous Sanctions Act 2011 to provide for the establishment of thematic sanctions regimes. Before this, Australia’s sanctions regimes have been mainly country-based. Explanatory Memorandum, Press Release, Press Release & Notice. Pursuant to the amendments, thematic regimes may relate …

Human RightsHuman Rights CorruptionCorruption Chemical WeaponsChemical Weapons Cyber-AttacksCyber-Attacks

US cyber sanctions designations & updated FinCEN guidance

Chatex, a virtual currency exchange, has been designated by the US Treasury Department’s Office of Financial Assets Control (OFAC) pursuant to Executive Order (E.O.) 13694 (cyber sanctions), as amended. It is alleged to have provided material support to the “threat posed by criminal ransomware attacks” and to SUEX OTC, S.R.O., a virtual currency exchange that was sanctioned by the US in …

Cyber-AttacksCyber-Attacks

OFAC publishes sanctions guidance for virtual currency industry

OFAC has published its ‘Sanctions Compliance Guidance for the Virtual Currency Industry’ (also available on the USA Guidance section of this site). Press Release and Notice. The guidance: Provides an overview of OFAC sanctions, requirements and procedures; Advises how to “block” digital currency following a designation (see also OFAC FAQ 646); Sets out sanctions compliance best practice for the virtual …

Cyber-AttacksCyber-Attacks

OFAC lists virtual currency exchange & issues ransomware advisory

SUEX OTC, S.R.O., a virtual currency exchange, has been sanctioned by the US Treasury’s Office of Foreign Assets Control (OFAC) for “facilitating financial transactions for ransomware attacks”, pursuant to Executive Order 13694 (cyber sanctions). It is the first time a virtual currency exchange has been designated by the US. OFAC Press Release and Notice. OFAC has also issued its ‘Updated …

Cyber-AttacksCyber-Attacks

Sanction regimes renewed, third countries align with EU sanctions & Kingpin Act designations

Over the past month, multiple sanctions regimes have been renewed around the world: The US renewed its regime in respect of Yemen for 1 year by continuing the national emergency as declared; The EU adopted: Council Decision (CFSP) 2021/796, which renewed its cyber-attacks sanctions regime until 18 May 2022; and Council Implementing Regulation (EU) 2021/848 and Council Decision (CFSP) 2021/855, …

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Current Sanctions

EU UK

Consolidated

Council Regulation (EU) 2019/796

Parent Regulation

Council Regulation (EU) 2019/796

Amended by:

Council Implementing Regulation (EU) 2020/1124

Council Implementing Regulation (EU) 2020/1536

Consolidated

Council Decision (CFSP) 2019/797

Parent Regulation

Council Decision (CFSP) 2019/797

Amended by:

Council Decision (CFSP) 2020/651

Council Decision (CFSP) 2020/1127

Council Decision (CFSP) 2020/1537

Council Decision (CFSP) 2021/796

The Cyber (Sanctions) (EU Exit) Regulations 2020 (SI 2020/597)