Practical Issues in Cyber-Related Sanctions
GIR: The Guide to Sanctions
In this chapter of Global Investigations Review: The Guide to Sanctions (Fifth Edition), authors Tim O"Toole, Laura Deegan, FeiFei Ren, Manuel Levitt, Annie Cho, and Rebecca Tweedie outline implications of cyber-focused sanctions primarily administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) in efforts to target malicious cyber-related activities such as cyber espionage, cyber-intrusions, and disinformation campaigns. They further discuss how companies can mitigate cyber-related sanctions risks. "Conducting an appropriate risk assessment and tailoring a risk-based compliance programme appropriately with sanctions compliance training for relevant personnel are essential steps in mitigating risk," the authors wrote. "Businesses of any size that utilise the internet, even if only for email, may face an increasing risk of ransomware attacks, which raises cyber-related sanctions compliance concerns."