On 8 July, the Global Investigation Review published this guide, saying that on 1 April 2015 President Obama issued EO 13694, which declared a national emergency to deal with ‘the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States constituted by the increasing prevalence and severity of malicious cyber-enabled activities originating from, or directed by persons located, in whole or in substantial part, outside the United States’. In December 2016, a further EO broadened the scope of the sanctions. Then, in August 2017, President Trump signed into law CAATSA, which authorised, inter alia, the imposition of cyber-related sanctions targeting Russia and codified the cyber-related sanctions imposed through the EO. The guide goes on to address practical issues that arise in the context of the sanctions regime.
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