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Office of Foreign Assets Control (OFAC) Cyber Attacks FinCEN

Kohrman Jackson & Krantz LLP

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

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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Benesch

Ransomware Response Complicated by Growing Number of Sanctions in Wake of Russian invasion of Ukraine

Benesch on

Entities facing significant legal risk, no matter the circumstances, if they make ransom payments to attackers connected to, or originating from Russia. As the Russian invasion of Ukraine continues, the U.S. government...more

Fenwick & West LLP

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

Fenwick & West LLP on

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

Orrick, Herrington & Sutcliffe LLP

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

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

Foodman CPAs & Advisors

OFAC Warns FFIs And Crypto Sector On Ransomware Attacks

Foodman CPAs & Advisors on

During the first half of 2021, 68 different ransomware attacks extracted approximately $600 million from victims across the United States. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) says that the...more

Davis Wright Tremaine LLP

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

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

Alston & Bird

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

Alston & Bird on

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

Proskauer - Blockchain and the Law

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Department of the Treasury Publishes Sanctions Review Results

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

Vinson & Elkins LLP

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

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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

Baker Donelson

New Ransomware Advisories from OFAC and FinCEN Create Additional Challenges for Financial Institutions

Baker Donelson on

Both the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury have issued advisories recently regarding regulatory considerations financial...more

Robinson+Cole Data Privacy + Security Insider

Update: Ransomware: To Pay or Not to Pay

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

King & Spalding

Patchwork of Cryptocurrency Regulators Increasingly Stitch Together Cooperative Enforcement Efforts

King & Spalding on

Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks - Amid...more

Skadden, Arps, Slate, Meagher & Flom LLP

Privacy & Cybersecurity Update - October 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

Foodman CPAs & Advisors

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

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

White and Williams LLP

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

White and Williams LLP on

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

ArentFox Schiff

OFAC’s New Ransomware Advisory

ArentFox Schiff on

On October 1, 2020, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an Advisory highlighting sanctions risks associated with facilitating ransomware payments on behalf of victims targeted by...more

Faegre Drinker Biddle & Reath LLP

Ransomware Payments May Violate Sanctions Laws, U.S. Treasury Department Warns

On October 1, 2020, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to companies that pay a ransom in the wake of a cyberattack. Specifically, the advisory warned that...more

Alston & Bird

FinCEN Alerts Financial Institutions on Role in Facilitating Ransomware Attacks

Alston & Bird on

With an increase in the frequency, sophistication, and cost of ransomware attacks, the Financial Crimes Enforcement Network (FinCEN) issued an advisory on October 1, 2020 alerting financial institutions to ransomware trends...more

Ballard Spahr LLP

To Pay or Not to Pay? Evolving Legal Considerations With Ransomware

Ballard Spahr LLP on

1. Overview of the regulatory issues facing companies—and cyber insurers—that may need to respond to ransomware emanating from a threat actor or group with potential ties to entities on federal lists.- The U.S. Treasury...more

WilmerHale

Enhanced North Korea Sanctions Adopted

WilmerHale on

The United Nations Security Council (“UNSC”) approved a Resolution last week imposing new sanctions against North Korea in response to its recent nuclear and missile tests. This UNSC action follows the enactment of the North...more

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