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Office of Foreign Assets Control (OFAC) Financial Institutions Cybersecurity

Jenner & Block

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

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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

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - December 2023 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Wilson Sonsini Goodrich & Rosati

Considerations for M&A Transactions Involving Fintech Companies

M&A transactions involving financial services providers—including tech-based providers or “fintechs”—raise a host of unique questions based on the types of services they provide, which are often highly regulated and may...more

K2 Integrity

Global Markets May Face Risk of Virtual Currency Abuse as Russian Actors Seek to Circumvent Sanctions

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The United States, the United Kingdom, and European Union have led a broad international coalition imposing a sweeping and unprecedented range of economic and financial sanctions against Russia and Belarus in response to...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

Saul Ewing LLP

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

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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

Alston & Bird

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

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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

Seyfarth Shaw LLP

OFAC Issues a New Advisory Memo on Potential Sanctions Risk for Facilitating Ransomware Payments

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On September 21, 2021 the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issue an updated memo on the potential sanctions risk associated with facilitating ransomware payments and to once again note...more

Ballard Spahr LLP

OFAC Targets Virtual Currency Exchange for Allegedly Facilitating Ransomware Attack

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On September 21, 2021 OFAC issued its first sanctions designation against a virtual currency exchange by designating the virtual currency exchange, SUEX OTC, S.R.O. (SUEX) “for its part in facilitating financial transactions...more

Akerman LLP

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

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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

Jones Day

OFAC Issues Additional Ransomware Guidance and Designates Virtual Currency Exchange

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The U.S. Treasury Department has issued an updated ransomware advisory that highlights sanctions risks associated with ransomware payments and details proactive steps companies can take to mitigate these risks....more

Bilzin Sumberg

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

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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

Sheppard Mullin Richter & Hampton LLP

NYDFS Issues Ransomware Guidance

The New York State Department of Financial Services recently announced new guidance addressing ransomware attacks, and highlighting cybersecurity measures to significantly reduce the risk of an attack. The guidance comes as...more

Husch Blackwell LLP

New York’s DFS Publishes A Cyber Insurance Risk Framework

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Keypoint: New York’s Division of Financial Services (DFS) now requires Property and Casualty Insurers writing cyber insurance to comply with the Division’s Cyber Insurance Risk Framework to manage their risk. In her...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

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

Jones Day

FinCEN Issues Guidance on Ransomware Attacks

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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

Neal, Gerber & Eisenberg LLP

Potential Sanctions Risks 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

Ballard Spahr LLP

FinCEN and OFAC Advisories Aim to Increase Cybersecurity Awareness and Thwart Ransomware Attacks in the Financial Sector

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October is National Cybersecurity Awareness Month, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) kicked off the month by issuing two...more

Lowndes

Dear Ransomware Victim and Your Accountants, Attorneys and Forensic Specialists: The Government Just Made Your Life Harder

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By now, most everyone knows that ransomware is software that infects your computer system, makes your data irretrievable and usually breaks things along the way. To unlock your system, the bad guys (or girls) demand you pay a...more

Bilzin Sumberg

OFAC Issues Regulatory Advisory Warning Against Facilitating Ransomware Payments

Bilzin Sumberg on

On October 1, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The Advisory, which does not carry the...more

Hogan Lovells

Treasury Department issues ransomware guidance in response to significant uptick in ransomware attacks

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In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more

BakerHostetler

OFAC Weighs in on Ransomware Payments but Stops Short of New Restrictions

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Ransomware has hit pandemic proportions and there does not seem to be a clear end in sight. On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory regarding ransom...more

Robinson & Cole LLP

Data Privacy + Cybersecurity Insider - October 2020

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CYBERSECURITY - 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...more

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