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Office of Foreign Assets Control (OFAC) Ransomware Financial Institutions

Foley Hoag LLP

Russia Sanctions Update - April 7, 2022

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I. New Executive Order Bans U.S. Investment in Russia - On April 6, 2022, President Biden issued a new Executive Order, “Prohibiting New Investment in and Certain Services to the Russian Federation 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

Morrison & Foerster LLP

Financial Services Report - Winter 2021

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Welcome to the Financial Services Report, holiday style! Banks and non-banks alike started early this year with additions and changes to their regulator stockings. The Senate confirmed Rohit Chopra as the new CFPB Director....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

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

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Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Sheppard Mullin Richter & Hampton LLP

Sanctions Compliance for Crypto: OFAC Issues Guidance Targeting Virtual Currency Industry

Last Friday, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. This guide comes on the heels...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

Baker Donelson

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

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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

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

Davis Wright Tremaine LLP

OFAC Warns of Sanctions Risks for Companies Facilitating Ransomware Payments

On October 1, 2020, the U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a new advisory spotlighting sanctions risks for companies that facilitate ransomware payments, including financial institutions, cyber...more

ArentFox Schiff

OFAC’s New Ransomware Advisory

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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

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

WilmerHale

Ransomware Attacks - Financial Crimes Compliance Requirements

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Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) each issued advisories addressing the risks associated with facilitating ransomware payments: the Advisory on Potential Sanctions Risks for Facilitating...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

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