Five Key Considerations Regarding New U.S. Sanctions to Address Ransomware Threats

On September 21, 2021, the U.S. Department of the Treasury (Treasury) Office of Foreign Asset Control (OFAC) imposed sanctions on a virtual currency exchange called Suex OTC, S.R.O. (Suex), and published an updated advisory on potential risks for those who facilitate ransomware payments. These coordinated actions represent significant moves by OFAC to target key aspects of the global ransomware ecosystem and to advance the U.S. government’s broader counter-ransomware strategy. By recommending strengthened cybersecurity measures and emphasizing reporting to law enforcement, OFAC’s updated advisory also reflects increasingly tighter collaboration among federal government agencies in their fight against the ransomware threat.