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: Data Security
Minimizing Risk and Liability from Man in the Middle Attacks (or, How to Keep Your Company’s Wire Transfers from Going Awry)
Imagine this scenario: you’ve had a productive and mutually advantageous ongoing contractual relationship of several years with another party. You have built up quite a bit of trust over the years, and communicate regularly over email. Your email communications include you receiving invoices and then confirming payment; your email messages might include a note about an upcoming shipment or provision of services, or even a note wishing the family well.… More