OFAC Updates Guidance On Ransomware Payments And Sanctions Risk

On Sept. 21, 2021, the Department of Treasury, Office of Foreign Assets Control (OFAC), updated its published guidance regarding sanctions risks associated with making ransomware payments and its official policy on such payments. This updated guidance, taken in conjunction with OFAC's recent sanctions designation of a cryptocurrency payment exchange frequently used for ransomware payments, and other ongoing regulatory legislative efforts to address ransomware attacks, further highlights the whole of government effort by the United States to discourage ransomware attacks and address the compliance responsibilities this effort continues to impose upon the business community.

Background on ransomware payments and sanctions