On April 1, 2015, President Obama issued an Executive Order (EO), establishing a new economic sanctions program, targeting individuals and entities who engage in certain types of cyber-crime and commercial espionage. Although economic sanctions are familiar policy tools, the EO represents an expansion of their use into a new field and provides new authority for the Departments of Treasury, State, and Justice to impose sanctions on primarily non-U.S. actors engaging in—or materially assisting or complicit in—malicious cyber activity, including thefts of trade secrets, and other misappropriation of economic information, that are considered to be a threat to the nation’s security, foreign policy, or the economy. For a complete summary, please click here.

 

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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice…

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations. He is experienced in providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws that can arise from the interaction between extraterritorial impacts of U.S. regulations and third country “blocking” laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.