On May 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated crypto mixer Blender.io as a Specially Designated National (“SDN”), marking the first time a virtual currency mixer has been sanctioned. The move is the latest in a series of sanctions designations and enforcement actions in the virtual currency
Office of Foreign Assets Control (OFAC)
Global Insurance Industry Year in Review 2021
Our Global Insurance Industry Year in Review is now in its 10th year. In this report, we discuss developments and trends in insurance industry transactions over the past year, with a particular focus on mergers and acquisitions, corporate finance, insurtech, the insurance-linked securities and convergence markets, as well as tax, regulatory and litigation developments.
A…
Cybersecurity Incident Response Developments and Trends for Financial Services Companies
2020 and 2021 saw sophisticated, coordinated cyber attacks affect some of the largest companies in the world. In the wake of these attacks, the Biden Administration and federal regulators—as well as businesses within the financial sector—are highly focused on cybersecurity. With a rapidly changing landscape, financial services companies are working hard to prepare for cyber…
OFAC Issues Updated Ransomware Advisory Emphasizing Reporting to and Cooperation with US Law Enforcement
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…
US Enforcement and Cybersecurity Outlook for Oil and Gas Companies
Oil and gas companies should anticipate a more vigorous enforcement environment during President Biden’s term, with anti-corruption and sanctions enforcement expected among some of the key areas of focus. In addition, companies should expect close scrutiny of the industry’s management of cyber risks, along with increased regulatory and litigation risk.
To help you navigate the…
OFAC and FinCEN Communicate Ransomware Expectations in New Guidance
On October 1, 2020, the US Treasury Department issued important guidance on what victims of ransomware attacks, as well as financial institutions (particularly money services businesses (“MSBs”) and other companies that facilitate such payments), should consider when confronted with potential ransomware demands. First, the Office of Foreign Assets Control (“OFAC”) issued an advisory that emphasizes…
President Obama Imposes Cyber-Related Sanctions in Response to Russian Interference in the 2016 US Election
On December 29, 2016, President Obama issued an executive order to authorize several actions in response to cyber activities of the Russian government that were related to the 2016 US election.1 The action receiving the most public attention was the imposition of primary economic sanctions on nine persons found to be responsible for or…