Ransomware and OFAC Sanctions Compliance
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 ransom payments. The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has a vested interest in this enforcement arena. On September 21, 2021, OFAC issued an updated ransomware advisory on the topic (“Updated Advisory”)....