The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
Understanding the Additional Risks When Making a Ransomware Payment
WorldSmart: The Extraordinary Sanctions Against Russia - What Happens Next?
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Compliance Perspectives: Sanctions, Data and Vetting Third Parties
FINCast Ep. 19 - The DPRK Sanctions Program
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
U.S. investors interested in investing in advanced Chinese technology companies may now be constrained by the U.S. Government’s first-ever outbound investment rule (Final Rule) which took effect on Jan. 2, 2025. The Final...more
You've been hit by a ransomware attack, and a cybercriminal group is demanding a cryptocurrency payment in exchange for your data's safe return. Should you pay? Deciding whether to pay a ransom is an internal business...more
The rise of ransomware attacks has prompted the international community to explore a range of approaches to deter these attacks, including the use of sanctions, the further development and instantiation of norms governing...more
Companies are increasingly choosing not to pay ransom for ransomware and extortionware due to the growing associated risks. In fact, a recent report by crypto-crime analyst firm Chainalysis found that payments to threat...more
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
1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...more
We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments. The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering...more
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
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
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
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
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
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
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released its Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (the “Updated Advisory”)....more
New regulatory activity may help companies experience fewer ransomware attacks and could impact whether ransoms can be paid to threat actors. The activity includes guidance and sanctions by the Department of Treasury...more
A ransomware attack is a major threat affecting all sectors of business, including healthcare. Organizations typically follow state and federal privacy laws as part of their ransomware prevention and response measures....more
1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties- Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department...more
On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more
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
Ransomware has emerged as one of the most virulent cybersecurity risks, affecting public and private sector alike. In recent years, ransomware attacks have become more focused, sophisticated, costly, and numerous. Threat...more
Ransomware demands have surged during the pandemic. Earlier this month, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an advisory pertaining to the financial implications of succumbing...more
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
Ransomware attacks – cyber attacks in which the hackers encrypt and disable an organization’s computers and demand a ransom to provide the decryption key – continue to hit organizations throughout the country. Perhaps even...more
In December of 2015 the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued regulations implementing the President’s April 1, 2015 Executive Order (“EO”), “Blocking the Property of Certain Persons...more
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