News & Analysis as of

Office of Foreign Assets Control (OFAC) Sanctions Ransomware

Dechert LLP

OFAC Sanctions Virtual Currency Mixer Tornado Cash

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The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more

A&O Shearman

Sanctions Roundup: Fourth Quarter 2021

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Closing the year with a renewed focus on the People’s Republic of China, the Biden Administration imposed new export restrictions on US-origin technology to Chinese tech firms to hinder the PRC’s military and security...more

Akin Gump Strauss Hauer & Feld LLP

Treasury to Companies: Time to Take Ransomware Reporting Seriously

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

Sheppard Mullin Richter & Hampton LLP

OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key

The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...more

Morrison & Foerster LLP

U.S. Government Takes Increasingly Aggressive Actions Targeting Ransomware

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On November 8, 2021, the U.S. Department of Justice (“DOJ”), U.S. Department of the Treasury (“Treasury”), and the U.S. Department of State (“State”) made several significant announcements regarding recent U.S. government...more

Lowenstein Sandler LLP

Trade Matters - November 2021

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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

Fisher Phillips

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

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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

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

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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

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

Bracewell LLP

OFAC Ransomware Update

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On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet...more

Morrison & Foerster LLP

DOJ Announces Renewed Focus on Export Control and Sanctions Enforcement

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In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more

Orrick, Herrington & Sutcliffe LLP

Treasury Actions to Counter Ransomware

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

Sheppard Mullin Richter & Hampton LLP

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

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

Morgan Lewis

OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

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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

Davis Wright Tremaine LLP

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

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

Foley Hoag LLP

Ransomware Payments – OFAC Updates its Advisory and Congress Gets Involved

Foley Hoag LLP on

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

Clark Hill PLC

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

Clark Hill PLC on

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

K2 Integrity

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

K2 Integrity on

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

Adams and Reese LLP

The Department of Treasury Issues Guidance Regarding Sanctions Risks Inherent to Facilitating Ransomware Payments

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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

Bracewell LLP

Ransomware Victims Told to Think Twice Before Paying Hackers

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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

Fenwick & West LLP

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

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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

Sheppard Mullin Richter & Hampton LLP

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

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

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

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

Foley Hoag LLP

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

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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

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