On 28 December 2016, the US President issued Executive Order (EO) 13757 to amend a 2015 EO authorising the US Treasury Department’s Office of Foreign Assets Control (OFAC) to impose sanctions for significant malicious cyber-enabled activities. Intended to address alleged Russian tampering in the US elections, EO 13575 expands the scope of the 2015 EO to include blocking sanctions against those found to be involved in “tampering with, altering or causing a misappropriation of information with the purpose or effect of interfering with or undermining election processes or institutions.” EO 13575 further imposes those sanctions against five entities and four individuals in the Russian Federation believed to be involved in malicious hacking. In coordination with that action, the Commerce Department’s Bureau of Industry and Security (BIS) added the five Russian entities to the Entity List, prohibiting exports, reexports and transfers (in-country) of all items subject to the Export Administration Regulations (EAR) without a BIS license.
