News & Analysis as of

Sanctions Cyber Crimes

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Proskauer - The Capital Commitment

The Trend Continues: Increased Regulatory Focus on Privacy & Cybersecurity for Private Funds

Recent enforcement actions highlight the increased regulatory scrutiny that private funds may face with respect to internal cybersecurity protocols and responses to cyber-crimes and cyber incidents under new and updated...more

Foley Hoag LLP - White Collar Law &...

2023 Trends in Criminal Tax Enforcement

This is the second part in our 2023 series examining important trends in white collar law and investigations. Up next: crypto enforcement. The days of decreased IRS enforcement activity may be coming to a close. Although...more

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

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

Foley Hoag LLP

Biden Administration Focus on Cybercrime Continues with Israeli Companies Added to Entity List, New Export Controls, and...

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On November 3, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added two Israeli entities to the Entity List due to malicious cyber activities. In its press release, BIS stated that the...more

K2 Integrity

Treasury Releases 2021 Sanctions Review

K2 Integrity on

On October 18, 2021, the U.S. Department of the Treasury released the 2021 Sanctions Review (“the Review”), which delineates Treasury’s framework for employing economic sanctions and provides key recommendations on...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

Clark Hill PLC

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

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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

Adams and Reese LLP

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

Adams and Reese LLP on

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

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

Alston & Bird

Russia Sanctioned For Role In SolarWinds Supply Chain Attack

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On April 15, 2021, the Biden Administration took a significant step in announcing sanctions against the Russian Government and private Russian entities for multiple internationally-destabilizing activities, including the...more

Husch Blackwell LLP

Biden Administration Imposes New Russia Sanctions And Establishes Framework For Future Expansion Of Russian Sanctions Regime

Husch Blackwell LLP on

Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned various individuals and entities connected to Russia’s technology sector and also expanded sanctions against dealings in Russian...more

Robinson+Cole Data Privacy + Security Insider

Recent FINRA Consent Agreement – Sanctions Against Former Securities Employee Regarding Wire Transfers

The regulatory sword of the financial industry came down on a former securities employee for violations involving wire transfers out of a client’s account. The Financial Industry Regulatory Authority (FINRA) provides...more

Foley & Lardner LLP

SEC Brings First Cybersecurity Enforcement Proceeding in Wake of Risk Alert

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Highlights Areas of High Risk and Examination Priorities for Financial Industry Firms - On September 15, the U.S. Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections and Examinations (OCIE),...more

King & Spalding

U.S., China Announce Cybersecurity Agreement During Xi Jiping’s Visit

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Chinese President Xi Jinping made his first state visit to the United States last week, and his itinerary included meetings with U.S. technology company leaders as well as President Barack Obama. Not surprisingly, his hosts...more

The Volkov Law Group

Checking In on Sanctions Enforcement

The Volkov Law Group on

The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement...more

Sheppard Mullin Richter & Hampton LLP

Keep Your Frenemies Close: Proposed China Sanctions and the Price of Escalation

On August 30, 2015, the Washington Post broke a story that the Obama administration is developing a package of economic sanctions that will target Chinese companies and individuals who have benefitted from cybertheft. The new...more

Orrick - Trade Secrets Group

U.S. Considers Sanctions Against China For Cyber Hacking And Trade Secret Misappropriation

You may have missed it this past weekend, but reports indicate the United States is considering sanctioning Chinese companies and individuals who have benefited from their government’s alleged cyber hacking of U.S. trade...more

Orrick, Herrington & Sutcliffe LLP

Policyholder Insider Quarterly

Five Lessons Health Care Companies Should Learn From Cyberattacks - The American health care industry is under attack by sophisticated hackers seeking access to electronic medical records. Since January, three health...more

Perkins Coie

President Issues Executive Order to Block Assets of Foreign Cyber Attackers

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President Obama recently issued Executive Order 13694 (EO 13694 or EO), “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities.” EO 13694 is aimed at deterring cyber attacks,...more

Orrick, Herrington & Sutcliffe LLP

United States Goes on the Offensive Against International Cybercrime - 2015 Cybersecurity Executive Order

On April 1, President Obama signed an Executive Order to combat the "national emergency" sparked by a rapidly evolving global cybercrime environment. The Executive Order directs the U.S. Treasury Department to impose...more

Morrison & Foerster LLP

Cyber Sanctions and National Security

In response to the growing cyber security threats from outside of the United States, the U.S. Government has added an entire new category of sanctioned individuals and organizations to its list of Specially Designated...more

Davis Wright Tremaine LLP

President Obama’s April Fools' Day Order on Cyberterrorism – No Joking About It!

While it’s not clear whether the President’s release today of an Executive Order, "Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities," was purposefully timed to coincide with...more

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