The U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) implemented additional measures today to combat the growing ransomware problem. OFAC’s measures consist of: (1) the designation of the entire SUEX OTC, S.R.O. (“SUEX”) crypto-currency exchange (SUEX) to the SDN List; (2) designating a fairly large number (~25) additional digital currency addresses to the SDN List; and (3) amending its earlier October 1, 2020 guidance to companies on the potential sanctions risks for facilitating ransomware payments. OFAC’s summary of the additional sanctions designations is available here and its updated guidance is available here.
While OFAC has previously designated … Continue Reading