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 -

Do You Know Who Your Employee Is? Mitigating DPRK IT Worker Risk

StoneTurn on 2/19/2025

North Korean IT operatives are infiltrating U.S. and Western companies using stolen or fabricated identities, VPNs, and U.S.-based co-conspirators to gain unauthorized access to corporate systems. These insider threats pose...more

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Skadden, Arps, Slate, Meagher & Flom LLP on 1/20/2025

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

OFAC Announces Sanctions Against Chinese-Based Cybersecurity Company

Alston & Bird on 1/14/2025

On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more

Financial Crimes Makes Debut in FINRA Annual Priorities Preview

Sheppard Mullin Richter & Hampton LLP on 1/18/2023

FINRA punctuated its annual post-New Year’s Report on FINRA’s Examination and Risk Monitoring Program (the “Report”), by including a new target category “Financial Crimes.” The inclusion of this category is noteworthy not...more

Trade Matters, February 2022: A monthly newsletter covering global trade & national security developments

Lowenstein Sandler LLP on 2/2/2022

1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...more

Treasury to Companies: Time to Take Ransomware Reporting Seriously

Akin Gump Strauss Hauer & Feld LLP on 12/14/2021

On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...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

Treasury Publishes U.S. Sanctions Policy Review and Framework for Future Action

Akin Gump Strauss Hauer & Feld LLP on 11/1/2021

On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more

Federal Authorities Warn Employers Against Ransomware Payouts and Offer New Guidance on Preventing and Responding to Cyberattacks

Fisher Phillips on 10/29/2021

Federal officials have recently warned employers and businesses that they could have insult added to injury if they respond to cyberattacks by making ransomware payments – increasingly requested through cryptocurrency – as...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

Treasury Actions to Counter Ransomware

Orrick, Herrington & Sutcliffe LLP on 10/13/2021

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more

Do You Have a Risk-Based Sanctions Compliance Program?: In the Event of a Ransomware Attack, OFAC Wants to Know

Sheppard Mullin Richter & Hampton LLP on 10/5/2021

In the wake of increased ransomware attacks over the course of the last several months, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has updated a guidance it released last year on potential...more

OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

Morgan Lewis on 10/4/2021

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more

OFAC Makes Waves in Fight Against Ransomware, but Practical Effects Unclear

Davis Wright Tremaine LLP on 10/4/2021

On September 21, 2021, the U.S. Department of the Treasury announced two major actions by the Office of Foreign Asset Control (OFAC) to combat ransomware: the release of OFAC's Updated Advisory on Potential Sanctions Risks...more

Ransomware Payments – OFAC Updates its Advisory and Congress Gets Involved

Foley Hoag LLP on 10/1/2021

Ransomware payments continue to be a focus of the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). As previously reported by Foley Hoag, on October 1, 2020, OFAC released an advisory regarding potential...more

OFAC Issues Updated Guidance on Paying Ransom – Buyer Beware of Sanction Risks

Clark Hill PLC on 9/30/2021

On Sept. 21, the Treasury’s Office of Foreign Assets Control (OFAC) issued an Advisory updating and superseding its previous advisory issued Oct. 1, 2020. OFAC is careful to note that the Advisory is not law, and does not...more

OFAC Releases Updated Ransomware Advisory and Announces First Designation of Cryptocurrency Exchange

K2 Integrity on 9/29/2021

On 21 September 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory that highlights the sanctions risks associated with making ransomware payments. OFAC reiterated...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 Victims Told to Think Twice Before Paying Hackers

Bracewell LLP on 9/24/2021

On Tuesday, the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued an updated advisory warning all ransomware victims that if they succumb to ransomware demands and pay foreign actors who are...more

OFAC Helps Those Who Help Themselves: How a Ransomware Response Plan Can Help Avoid Sanctions Enforcement for Ransom Payments

Fenwick & West LLP on 9/24/2021

Many companies have a “no ransomware payment” stance until faced with a ransomware attack, especially an attack that causes significant business disruption. At that point, the company may reconsider its stance (or at least...more

First OFAC Sanctions Against a Cryptocurrency Exchange: Could the Designation of SUEX Signal an Enforcement Trend to Combat...

Sheppard Mullin Richter & Hampton LLP on 9/23/2021

On September 21, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on SUEX OTC, S.R.O, a cryptocurrency exchange, for its role in laundering money to ransomware attackers. According...more

Trade Matters - Lowenstein Sandler's Global Trade & Policy Newsletter - June 2021

Lowenstein Sandler LLP on 6/3/2021

1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties- Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department...more

Biden Administration Issues Sweeping New Sanctions On Russia In Response To Election Interference, Malicious Cyber Activity, And...

Morrison & Foerster LLP on 4/20/2021

On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more

President Biden Gets Tough on Russia with New Executive Order

Holland & Hart LLP on 4/19/2021

President Biden issued yesterday an Executive Order imposing sweeping sanctions on Russia in response to Russia’s cyberespionage campaign against the United States, efforts to influence the 2020 presidential election, its...more

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Cybersecurity › Sanctions › Office of Foreign Assets Control (OFAC)

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