News & Analysis as of

Office of Foreign Assets Control (OFAC) Hackers International Emergency Economic Powers Act (IEEPA)

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more

Patton Sullivan Brodehl LLP

The “DAO Jungle” Chronicles: Federal Judge Upholds Treasury Department’s Sanction of Tornado Cash for Involvement in Laundering...

In two prior posts, this blog tracked the ongoing intrigue of how the various branches of the United States government interact with blockchain and cryptocurrency organizations. We discussed the Wyoming law allowing...more

Foley & Lardner LLP

White House Issues Open Letter to Private Businesses Regarding the Threat of Ransomware

Foley & Lardner LLP on

On June 2, 2021, Anne Neuberger, Deputy Assistant to the President and Deputy National Security Advisor for Cyber and Emerging Technology, published a rare open letter to the corporate executives and business leaders of...more

King & Spalding

Ransomware on the Rise in Critical Infrastructure Sector

King & Spalding on

Recent ransomware attacks against U.S. critical infrastructure, which includes the energy sector’s production of oil and natural gas, and other sources of electricity and power, have shed a spotlight on the importance of...more

Foley Hoag LLP

First A Ransomware Attack, Now Sanctions? New OFAC Advisory Warns of Sanctions Risks for Facilitating Ransomware Payments

Foley Hoag LLP on

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an advisory regarding potential sanctions risks related to facilitating ransomware payments... OFAC is the federal...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

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