Today, OFAC is also designating nine Iran-based individuals who were leaders, contractors, associates, hackers for hire, and affiliates of the Mabna Institute for engaging in malicious cyber-enabled activities related to the significant misappropriation of economic resources or personal identifiers for private financial gain. Mostafa Sadeghi (Sadeghi) was a hacker and affiliate of the Mabna Institute. Sadeghi compromised more than 1,000 university professor accounts. Sadeghi exchanged credentials for compromised professor accounts with other Mabna-affiliated actors. Sadeghi was also involved in the operation of, and maintained a financial interest in, one of the websites selling access to the stolen university data.
Executive Order 13694 Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities;
Executive Order 13757 Taking Additional Steps to Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities
On December 31, 2015, OFAC issued the Cyber-Related Sanctions Regulations, 31 CFR part 578 (80 FR 81752, December 31, 2015) (the “Regulations”) to implement Executive Order (E.O.) 13694 of April 1, 2015, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities” (80 FR 18077, April 2, 2015), pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13694. The Regulations were initially issued in abbreviated form for the purpose of providing immediate guidance to the public. OFAC is revising the Regulations to further implement E.O. 13694, as amended by E.O. 13757 of December 28, 2016, “Taking Additional Steps to Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities” (82 FR 1, January 3, 2017), as well as certain provisions of title II of the Countering America's Adversaries Through Sanctions Act (Pub. L. 115–44, 131 Stat. 886 (codified in scattered sections of 22 U.S.C.)) (CAATSA). OFAC is amending and reissuing the Regulations as a more comprehensive set of regulations that includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.
E.O. 13694, as Amended by E.O. 13757. On April 1, 2015, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), issued E.O. 13694. In E.O. 13694, the President determined that 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 constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States, and declared a national emergency to deal with that threat.
On December 28, 2016, the President issued E.O. 13757 to take additional steps to deal with the national emergency with respect to significant malicious cyber-enabled activities declared in E.O. 13694. E.O. 13757 added an Annex to E.O. 13694 and amended section 1 of E.O. 13694 by replacing section 1(a) in its entirety.
