Ransomware payments continue to be a focus of the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). As previously reported by Foley Hoag, on October 1, 2020, OFAC released an advisory regarding potential sanctions risks related to facilitating ransomware payments. Almost a year later, on September 21, 2021, OFAC updated its advisory to provide additional guidance regarding what OFAC considers to be mitigating factors if facilitating a ransomware payment results in an apparent violation of U.S.… More
Category Archives: Congress
This is the fourth in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed anti-corruption enforcement. Up next, SEC on ESG Risk Disclosure – Moving From “If” to “How”.
With President Biden in the White House and Democrats controlling both chambers of Congress, the private sector should expect increased scrutiny through congressional investigations used to probe perceived wrongdoing and support an ambitious legislative agenda.… More