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Cybersecurity Compliance on U.S. Government Contracts and Subcontracts

By Karen Harbaugh and Richard Gibbon on Posted in cybersecurity, Department of Justice, False Claims Act (FCA), Fraud, ransomware, United States, US Department of Justice, Whistleblowing
The U.S. Department of Justice announced late last year that it would utilize the False Claims Act, the U.S. government’s primary civil tool to redress false claims for federal funds and property, to bring actions against U.S. government contractors and subcontractors who do not meet the cybersecurity requirements of a particular contract or grant. The … Continue Reading

OFAC Issues Updated Ransomware Advisory and Designates Virtual Currency Exchange

By Kevin McCart and Sassi Riar on Posted in Compliance Program, cybersecurity, OFAC, ransomware, Sanctions
On September 21, 2021, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (the “Updated Advisory”) superseding its earlier October 1, 2020 guidance on ransomware attacks and, for the first time, added a virtual currency exchange to the Specially … Continue Reading

4 Compliance Tips Amid Increased Ransomware Scrutiny

By Colin Jennings and Ericka Johnson on Posted in anti-money laundering, anti-terrorism financing laws, Compliance Program, cyberattack, cybersecurity, Data Protection & Privacy, FinCEN, OFAC, ransomware, US Treasury
In light of two new US Treasury Department advisories signaling increased oversight of ransomware payments, victim companies and their third-party response teams considering making payments should follow certain due diligence and compliance best practices, write Colin Jennings, Ericka Johnson, Dylan Yépez and Elizabeth Weil Shaw in an article for Law360.… Continue Reading

Ransomware Payments can lead to Sanctions and Reporting Obligations for Financial Institutions

By Kevin McCart on Posted in Bank Secrecy Act, cyberattack, cybersecurity, Data Protection & Privacy, Economic sanctions, FinCEN, OFAC, ransomware, Sanctions
With cybercrime on the rise, two U.S. Treasury Department components, the Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”), issued advisories on one of the most insidious forms of cyberattack – ransomware.… Continue Reading
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