News & Analysis as of

Office of Foreign Assets Control (OFAC) Risk-Based Approaches

WilmerHale

Building Ransomware Resilience - A Proactive Strategy for Businesses and Regulators

WilmerHale on

The rise of ransomware attacks has prompted the international community to explore a range of approaches to deter these attacks, including the use of sanctions, the further development and instantiation of norms governing...more

Pillsbury - Policyholder Pulse blog

The Dangers of Dialogue: Ransomware Attackers Want to See Your Cyber Insurance Policy

Amidst the recent surge in ransomware attacks on U.S. businesses—with crypto criminals and sometimes State actors invading and encrypting computer and operating systems and extorting funds in exchange for the decryption...more

The Volkov Law Group

Assessing Third-Party Sanctions Risks (Part II of III)

The Volkov Law Group on

The task of designing appropriate third-party sanctions controls requires reverse engineering of relevant caselaw, particularly, the Epsilon Electronics case, which I reviewed in Part I of this series, and the Department of...more

The Volkov Law Group

OFAC Settles with Hong Kong Trading Company for $5.2 Million for Violations of Iran Sanctions Program

The Volkov Law Group on

OFAC is off to a quick start in 2022.  After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more

The Volkov Law Group

Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency

The Volkov Law Group on

In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry.  For seasoned compliance veterans, it ends up reading like a refresher...more

Akerman LLP

New OFAC Advisory Offers Steps to Reduce Sanctions Risks for Entities Facilitating Ransomware Payments

Akerman LLP on

Companies that make ransomware payments, whether they be the victim of a ransomware attack or entities that facilitate such payments, should review the updated advisory issued by U.S. Department of the Treasury's Office of...more

Bilzin Sumberg

OFAC Warns Companies Again Not to Pay Ransomware Demands and Offers Helpful Hints for Mitigating Risks

Bilzin Sumberg on

On September 21, 2021, The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Updated Advisory “to highlight the sanctions risks associated with ransomware payments in connection with malicious...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Releases Advisory on Sanctions Risk Involving Ransomware Payments

In early October, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory, warning of the potential risk of sanctions to companies and individuals who pay ransomware payments. The...more

Robinson+Cole Data Privacy + Security Insider

OFAC Issues Advisory on Sanctions for Facilitating Ransomware Payments

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory “to highlight the sanctions risks associated with ransomware payments related to malicious cyber-enabled...more

Snell & Wilmer

FinCEN, OFAC and the IRS Place Virtual Currencies Under a Real-World Regulatory Microscope

Snell & Wilmer on

The Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) have recently stepped up the pressure on virtual currency companies. Increased regulatory scrutiny has largely taken the...more

Foodman CPAs & Advisors

Deficiencies or Weaknesses in an OFAC Sanctions Compliance Program can lead to OFAC Administrative Actions

On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”.  The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more

Foodman CPAs & Advisors

Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

Ballard Spahr LLP

AMA Updates AML Best Practices for AML Compliance

Ballard Spahr LLP on

AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more

Foodman CPAs & Advisors

¿Su institución financiera utiliza un “Matrix” de enfoque basado en el riesgo de la OFAC?

El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas.  Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more

Foodman CPAs & Advisors

Does your Financial Institution utilize OFAC’s Risk Based Approach Matrix?

A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations.  A Financial Institution’s OFAC compliance program is required to...more

Foodman CPAs & Advisors

El Programa de Cumplimiento de Sanciones de la OFAC le aplica a todos

OFAC (Oficina de Control de Activos Extranjeros) es un departamento del Tesoro de los Estados Unidos que administra y aplica sanciones económicas y comerciales basadas en la política exterior de los Estados Unidos y los...more

Foodman CPAs & Advisors

The OFAC Sanctions Compliance Program applies to all

OFAC (Office of Foreign Assets Control) is a department of the US Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals.   ...more

Foley & Lardner LLP

Top Compliance Issues Facing Manufacturers in 2016

Foley & Lardner LLP on

In the last several years, the U.S. has been aggressively enforcing laws governing exports and international conduct. This is amply illustrated by the continuing imposition of large penalties on multinational companies for...more

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