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Building Ransomware Resilience - A Proactive Strategy for Businesses and Regulators

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

OFAC Imposes New Sanctions to Thwart Ransomware

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Ransomware Attacks - Financial Crimes Compliance Requirements

Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) each issued advisories addressing the risks associated with facilitating ransomware payments: the Advisory on Potential Sanctions Risks for Facilitating...more

OFAC Identifies Digital Currency Addresses in Sanctions Designations and Provides FAQs on Digital Currency Compliance

On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more

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