Virtual Currency Platforms And Ransomware Attacks: OFAC Highlights Overlap Of Sanctions And Cybersecurity Risks

In the past month, the Office of Foreign Assets Control (OFAC) of the US Department of Treasury (Treasury) has issued two advisories that highlight the heightened US sanctions risk associated with cyber related activities, including ransomware attacks and the virtual currency platforms that ransomware payers often use to facilitate payments.

As the scale of cyber related—and, specifically, ransomware—attacks has steadily increased over the past several years, they are now at an all-time high, prompting the Biden Administration to make cybersecurity an increasing focus. According to Treasury, ransomware payments in the first half of 2021 totaled $590 million, exceeding the reported value of $416 million for the entirety of 2020. To this point, Treasury, in releasing its 2021 Sanctions Review, observed that "while sanctions remain an essential and effective policy tool, they also face new challenges" that include "rising risks from new payments systems, the growing use