Five Key Considerations Regarding New U.S. Sanctions to Address Ransomware Threats

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On September 21, 2021, the U.S. Department of the Treasury (Treasury) Office of Foreign Asset Control (OFAC) imposed sanctions on a virtual currency exchange called Suex OTC, S.R.O. (Suex), and published an updated advisory on potential risks for those who facilitate ransomware payments. These coordinated actions represent significant moves by OFAC to target key aspects of the global ransomware ecosystem and to advance the U.S. government’s broader counter-ransomware strategy. By recommending strengthened cybersecurity measures and emphasizing reporting to law enforcement, OFAC’s updated advisory also reflects increasingly tighter collaboration among federal government agencies in their fight against the ransomware threat.

Background

Ransomware attacks use malware, often injected through phishing schemes, to infect a victim’s computer system and to restrict the victim from accessing the system, stored data, or files by encrypting them. These attacks are typically followed by a ransom demand by the threat actor that offers the decryption key in exchange for payment. Threat actors usually demand payment in cryptocurrencies (like bitcoin); accordingly, victims often use…

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