On December 29, 2016, President Obama issued an executive order to authorize several actions in response to cyber activities of the Russian government that were related to the 2016 US election.1 The action receiving the most public attention was the imposition of primary economic sanctions on nine persons found to be responsible for or complicit in malicious cyberattacks designed to interfere with the election.2 The imposition of these sanctions marks the first time that the president has used his wide-ranging authority to sanction companies and individuals for engaging in or supporting cybercrime. All US persons and many non-US persons who are contractually or otherwise required to comply with US sanctions laws are now prohibited from directly or indirectly doing business with the sanctioned persons.

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