President Issues Executive Order Establishing New Sanctions Regime to Combat Cyber Attack Threats

On April 1, 2015, President Obama issued Executive Order 13694, which effectively establishes a new sanctions regime designed to combat cyber-attack threats. Specifically, this Executive Order grants authority to the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State, to impose sanctions on individuals and entities that are found to be responsible for or complicit in “cyber-enabled activities…that are reasonably likely to result in, or have materially contributed to, a significant threat to the national security, foreign policy, or economic health or financial stability of the United States.” In conjunction with the issuance of Executive Order 13694, materials discussing its intended effect and implications have been issued by the White House and the U.S. Treasury Department.

Executive Order 13694 has already garnered substantial attention due in part to the potential for its broad application and because it further demonstrates the Administration’s prioritization of cybersecurity issues. It is too early at this juncture to predict how extensively this new cybersecurity sanction regime will be applied or if it will be effective at deterring cyber threats, but developments resulting from Executive Order 13694 are likely to be hot topics going forward.