Cyber related sanctions

Information as of: 15th May 2020

Latest Updates
UN
US  On the 30 March 2020 all restrictive measures under EO 13694 were renewed for a further year.
EU/UK Measures stated under Council Regulation (EU) 2019/796 have been extended until 18 May 2021 under (CFSP) 2020/651.
Financial/Other Sanctions
UN
US EO 13694 01 Apr 2015, amended by EO 13757 28 Dec 2016
EU/UK EU / UK: WEF 17 May 2019 Council Regulation (EU) 2019/796 puts in place the framework for travel bans and asset freezing measures to be imposed on those “responsible for cyber-attacks or attempted cyber-attacks, who provide financial, technical or material support for such attacks or who are involved in other ways”. UK has put in place the  Cyber-Attacks (Asset-Freezing) Regulations 2019 which transpose the EU sanctions into UK law WEF 11 Jun 2019. Measures stated under Council Regulation (EU) 2019/796 have been extended until 18 May 2021 under (CFSP) 2020/651.
Arms Embargo
UN No
US No
EU/UK No
Further Details
UN
US EO 13694 01 Apr 2015 allows for the blocking of property of persons engaging in malicious cyber-enabled activities. Amended by EO 13757 28 Dec 2016, which allows for further sanctions related to cyber activities to be imposed and added individuals and entities to the SDN list. 15 Mar 2018, 13 individuals and 3 entities related to Russian interference in 2016 elections and malicious cyberattacks added to the list. Cyber related General License also updated 15 Mar 2018. 23 Mar 2018, 10 Iranian individuals and 1 entity designated for malicious cyber activities. 11 Jun 2018, several Russian firms and individuals designated under the EO and CAATSA for providing support to the Federal Security Bureau (FSB).  On the 30 March 2020 all restrictive measures under EO 13694 were renewed for a further year.
EU/UK
This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.