Do You Have a Risk-Based Sanctions Compliance Program?: In the Event of a Ransomware Attack, OFAC Wants to Know

In the wake of elevated ransomware assaults over the course of the final a number of months, the US Division of Treasury’s Workplace of Overseas Property Management (OFAC) has updated a steerage it launched last year on potential sanction dangers if facilitating ransomware funds. As indicated in the authentic steerage, OFAC has designated a number of risk actors as “malicious cyber attackers,” together with the builders of Cryptolocker, SamSam, WannaCry, and Dridex. OFAC has indicated that it’ll impose sanctions on those that financially (or in any other case help) these actors, together with by making ransomware funds to them. Sanctions can vary from personal (for instance No Motion Letters or Cautionary Letters) to public actions (together with for instance cost of civil financial penalties).

In this new steerage, OFAC has indicated what components can be “more likely” lead to the matter closing with a personal motion. They’re enhancing cyber safety practices prior to an incident and dealing intently with regulation enforcement in the occasion of an incident. Enchancment measures talked about by the steerage embrace conserving backups (offline), having an incident response plan, conducting coaching, updating virus software program, utilizing authentication protocols, and in any other case following the Cybersecurity and Infrastructure Safety Company’s 2020 guide on ransomware. In different phrases, a risk-based compliance program to mitigate potential publicity if a firm finds itself in a place of potential publicity to sanctions’ violations. This steerage got here on the heels of OFAC’s sanctions of a cryptocurrency for its involvement in cost to ransomware risk actors (see article on our sister weblog).

Placing It Into Apply: Is your group ready for a potential cyber incident? The cyber safety practices outlined in OFAC’s information can’t solely assist a firm be ready for a potential incident, but in addition put it in a higher posture in the occasion a ransomware demand is made.

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