On December 31, 2015, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) issued the Cyber-Related Sanctions Regulations to formally implement the sanctions set forth by President Obama last April in Executive Order 13694.  As we previously reported the Executive Order for the first time imposes sanctions on persons engaged in “significant malicious cyber-enabled activities” that harm U.S. interests.  The new regulations are effective immediately.  OFAC has yet to designate any person under this sanctions program, but the issuance of these regulations suggests that designations may be forthcoming.