Archive for the ‘Cyber Sanctions’ Category



OFAC Answers Call To Fix Unintended Result of FSB Designation

Posted by at 6:35 pm on February 2, 2017
Category: Cyber SanctionsOFAC

Vladimir Putin via [Fair Use]In an earlier post, I pointed out an unintended consequence of the designation of the Vladimir Putin’s spy masters, the FSB, by the Office of Foreign Assets Control to punish the FSB for meddling in the last election. The problem was the designation would prohibit exports of encryption-enabled products like mobile phones by U.S. companies to Russia. Such exports require either the approval of, or notification to, the FSB prior to the import of such items into Russia, either of which would be forbidden as a result of the designation. I suggested that OFAC was unaware of this requirement and that, as it did in a similar situation in Crimea, OFAC would likely issue a general license to permit dealing with FSB for the limited purpose of such exports to Russia.

Well, I’m awarding myself the Jeanne Dixon Psychic of the Year award, because that is exactly what OFAC did earlier today. The new General License No. 1 issued relative to Executive Order 13694 authorizes applications to, and notifications of, the FSB in connection with “the importation, distribution, or use of information technology products in the Russian Federation.” Needless to say, the general license makes clear that items subject to the EAR still require any necessary authorizations from the Bureau of Industry and Security such as, for example, an authorization under license exception ENC. Exports of these products to Crimea are also, not surprisingly, not permitted by the new general license.

(Side note on Jeanne Dixon who claimed to have predicted JFK’s assassination: She used to live in a townhouse on 19th Street, NW, in Washington, DC, not far from where I was working at the time. The gate outside the house had two plaster lions perched on the columns on either side of the gate. One day the lions mysteriously went missing. Several days later a handwritten sign was posted on the gate offering a significant reward for the safe return of the lions. Almost immediately some wag — not me, I promise — wrote on the reward sign: “If you’re psychic, find them yourself!” The sign disappeared and the lions never returned.)

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