Ransomware and Sanctions in the Time of War

Since 2020, the number and sophistication of ransomware attacks has spiked, largely perpetuated by organized criminal groups in Russia and Eastern Europe. Against this backdrop lies the U.S. government’s position on economic sanctions implemented by the U.S. Department of the Treasury – which have escalated since Russia’s attack on Ukraine – prohibiting U.S. persons from making payments directly or indirectly to any individual, entity, group or country that is the target of such sanctions. In this guest article, Greenberg Traurig shareholders Jena Valdetero, Kara Bombach and Kyle Freeny discuss today’s most prevalent types of ransomware attacks, considerations for whether to make the ransom payment, FinCEN and OFAC’s ransomware guidance, and the U.S. government’s mitigation efforts. See “Ten Tips to Prepare for and Navigate Ransomware Decisions” (Jan. 12, 2022).

To read the full article

Continue reading your article with a CSLR subscription.