Key takeaways

• 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.