On September 21, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions intended to “advance the United States government’s broader counter-ransomware strategy,” including an update to OFAC’s October 2020 advisory on ransomware payments and the first Specially Designated National (“SDN”) designation of a virtual currency exchange. OFAC’s action is part of what it described as a “whole of government” approach to combatting the threat posed by ransomware and, indeed, its updated advisory represents a unique effort to leverage OFAC’s potential enforcement authority to encourage ransomware victims to report ransomware incidents to, and cooperate with, law enforcement.

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