Building Ransomware Resilience: A Proactive Strategy For Businesses And Regulators

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 cyberattacks, and the promotion of cybersecurity best practices.

Sanctions have been an important part of the toolkit used by government agencies to impose costs on ransomware actors. In February 2023, regulators in the UK and the US Treasury Department's Office of Foreign Assets Control (OFAC) sanctioned seven members of the Russian-based cybercrime gang TrickBot, associated with Russian Intelligence Services, for deploying ransomware to target critical infrastructure in both countries. In August 2022, OFAC sanctioned Tornado Cash, a decentralized cryptocurrency mixer, for allegedly facilitating the laundering of $7 billion in virtual currency (VC). In a similar move, in September 2021, OFAC designated SUEX OTC, S.R.O. (SUEX), a