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Over the last few months, US economic sanctions have taken the front pages as the Trump Administration has reinstated certain sanctions aimed at Iran following the United States withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”). While the so-called “snapback” reinstated sanctions provisions increase the risk for non-US companies, recent enforcement actions against non-US companies demonstrate that such companies have always been at risk of violating the US sanctions laws.…
On April 1, 2015, President Obama issued Executive Order 13694, creating a new sanctions program that targets the growing and evolving threat posed by cyber-attacks.  The Order authorizes sanctions against those who seek to use cyber-attacks to harm critical infrastructure, target network availability, and steal sensitive information, such as trade secrets and personal financial information. The Order requires the freezing of assets of designated cyber-attackers in the United States or in the control or…