On December 29, 2016, the US government announced several measures in response to the Russian government’s alleged “aggressive harassment of U.S. officials and cyber operations aimed at the U.S. election.” The measures impose sanctions against nine Russian parties, including the Russian Federal Security Service (“FSS” or “FSB”). In addition, the US government announced the expulsion of 35 Russian diplomats from the United States and the closing of two US properties for their alleged intelligence operations. As a result of the sanctions, US companies will now likely require US government authorization prior to dealing with the FSB, which can include submissions to or the receipt of approvals from the FSB to market or distribute certain encryption products in Russia or participation in certain other regulatory actions before the FSB.
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