Skip to content

menu

Open Legal Blog Archive logo
HomeAboutBlogsFAQsSubmit

OFAC Issues Updated Guidance on Ransomware Attacks and Imposes First Sanctions Designation on a Virtual Currency Exchange

By Caroline Brown, Laura Foggan, Carlton Greene, Jeffrey L. Poston, Dj Wolff, Evan D. Wolff, Maida Oringher Lerner, Anand Sithian & Matthew B. Welling on September 28, 2021

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated advisory on potential sanctions risks for companies that facilitate ransomware payments in response to cyberattacks, guidance on preventative measures companies can implement to mitigate such risks, and criteria that OFAC will consider as mitigating factors in any potential enforcement action. OFAC also announced that it has added SUEX OTC, S.R.O. (“SUEX”), a Russian virtual currency exchange, to its Specially Designated Nationals and Blocked Persons List (the “SDN List”), as a result of its role in facilitating ransomware payments. This represents OFAC’s first-ever designation of a virtual currency exchange.

Click here to continue reading the full version of this alert.

  • Posted in:
    International
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

Open Legal Blog Archive, Inc. logo
Seattle, Washington
Copyright © 2026, Open Legal Blog Archive, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo