News & Analysis as of May 5, 2025

Office of Foreign Assets Control (OFAC)

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

The Wallet Inspectors: The DPRK’s Sophisticated Campaign to Steal Cryptocurrency and How to Protect Yourself

Faegre Drinker Biddle & Reath LLP on 3/6/2025

On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered a cyberattack resulting in the theft of approximately $1.5 billion in Ethereum tokens. This attack marked a new pinnacle in the...more

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

Jenner & Block on 1/12/2024

As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

You’ve Been Hit by Ransomware: What Should You Do?

Kohrman Jackson & Krantz LLP on 8/19/2022

Despite your best efforts, you have been hit by ransomware. You are locked out of your system, and you can provide no services to your customers, clients or patients. From a business perspective, you need to get your system...more

OCC Highlights Risks Associated with Compliance Staffing Concerns, Russia Sanctions, Environmental Crimes, Cyber Attacks and...

Ballard Spahr LLP on 6/30/2022

On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022. In the SRP, the OCC opines on its current safety and soundness concerns for banks under...more

To Pay or Not to Pay: Five Critical Approaches to Beating a Ransomware Threat

Fenwick & West LLP on 4/1/2022

It’s the call you hope you never get. Your company has been hit with a ransomware attack. Your systems are offline. Your customer data was stolen by an unknown threat actor who is threatening to leak it. You have lots of...more

Corporate Governance 2021 Year in Review (and a First Look at 2022)

Kramer Levin Naftalis & Frankel LLP on 1/6/2022

2021 was a busy year for corporate governance matters, with new legislation passed early in the year and new enforcement priorities emerging under the Biden administration. Kramer Levin lawyers published numerous articles...more

Year-end Crypto Roundup — Five Key Concepts About the U.S. Government’s Recent Actions on Virtual Currency and Ransomware

Orrick, Herrington & Sutcliffe LLP on 12/30/2021

The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more

"Whole of Government" Anti-Ransomware Campaign on Full Display

Davis Wright Tremaine LLP on 11/24/2021

November 8, 2021, may have been the most significant single day in the United States' "whole of government" anti-ransomware campaign. The Department of Justice, Department of the Treasury, and Department of State all...more

The Digital Download – Alston & Bird’s Privacy, Cyber & Data Strategy Newsletter – November 2021

Alston & Bird on 11/19/2021

Selected Developments in U.S. Law - Department of Defense Suspends the CMMC Pilot Program and CMMC Requirements in DoD Solicitations Pending Major Changes for CMMC 2.0. On November 5, 2021, the Department of Defense...more

Revised FinCEN Advisory Warns Financial Institutions to Report Suspected Illegal Ransomware Payments

Saul Ewing LLP on 11/17/2021

The U.S. Federal Government through its Financial Crimes Enforcement Network (“FinCEN”) revised last year’s Advisory on the Use of the Financial System to Facilitate Ransom Payments. In short, the U.S. Government is...more

Trade Matters - November 2021

Lowenstein Sandler LLP on 11/3/2021

1. New Cybersecurity Export Controls From BIS Go Into Effect in January - The Bureau of Industry and Security (BIS) has released an interim final rule establishing new export controls on certain cybersecurity items and...more

US Department of the Treasury Publishes Sanctions Review Results

Skadden, Arps, Slate, Meagher & Flom LLP on 10/27/2021

On October 18, 2021, the U.S. Department of the Treasury released the results of its broad review of economic and financial sanctions. The review, initiated by the Biden administration, included discussions with Congress,...more

OFAC Puts Virtual Currency Industry On Notice

King & Spalding on 10/26/2021

Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more

FinCEN Reports Spiraling SARs Relating to Ransomware

Ballard Spahr LLP on 10/22/2021

On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

Alston & Bird on 10/20/2021

On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more

The Department of Treasury Issues Guidance Regarding Sanctions Risks Inherent to Facilitating Ransomware Payments

Adams & Reese on 9/28/2021

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more

Ransomware – A Pandemic In The Dark Web Signals A Need To Vaccinate Your Compliance Program

Vinson & Elkins LLP on 2/12/2021

Two weeks ago, the Department of Justice (“DOJ”) announced two significant enforcement actions and shut down NetWalker and Emotet, powerful tools that had been used by alleged criminal networks engaging in widespread...more

NYDFS Announces Cyber Insurance Risk Framework to Address Increasing Cyber Risk

White and Williams LLP on 2/8/2021

Even if your company does not report to the New York Department of Financial Services (DFS), all insurers should heed warning to prepare for future cyber risk regulations and requirements. Cyber risk is real and has the...more

Don’t You (Forget About Me 2020): Cybersecurity Developments for 2020 in Five Musical References

White and Williams LLP on 1/13/2021

Is it hyperbolic to say that never before have we seen a quieter, yet more anticipated and welcome end to a year than in 2020? For some, 2020 is a year the sooner forgotten, the better. In data privacy and security law, a lot...more

Update: Ransomware: To Pay or Not to Pay

Robinson+Cole Data Privacy + Security Insider on 12/3/2020

Three recent events are prompting me to update our previous blog post on the difficult decision of whether to pay or not to pay ransomware following an attack....more

Privacy & Cybersecurity Update - October 2020

Skadden, Arps, Slate, Meagher & Flom LLP on 11/3/2020

In this month's edition of our Privacy & Cybersecurity Update, we examine the U.S. Treasury's advisories regarding the role of financial intermediaries in ransomware payments, a ruling by the Israeli data protection authority...more

Financial Institutions to Remain Vigilant of Ransomware Attacks as they are Facilitators of Ransomware Payments

Foodman CPAs & Advisors on 11/3/2020

On October 1, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advisory to alert Financial Institutions (FI) relating to “predominant trends, typologies, and potential indicators of ransomware and associated...more

Federal Advisory Warns Hospitals Facing “Increased and Imminent” Cyber Threat; 400 Hospitals Already Targeted

White and Williams LLP on 11/2/2020

A Joint Cybersecurity Advisory (the Advisory) by the Cybersecurity & Infrastructure Security Agency (CISA), the Federal Bureau of Investigation (FBI) and the Department of Health & Human Services (HHS) has warned of an...more

FinCEN Issues Guidance on Ransomware Attacks

Jones Day on 10/23/2020

The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more

Paying or Facilitating Payment of Ransomware Demands May Result in Criminal and Civil Penalties From OFAC

Saul Ewing LLP on 10/9/2020

Companies that make or facilitate ransomware payments were given a strong reminder of their due-diligence and compliance obligations by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). ...more

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