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The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen, the head of the Treasury department, criticizing digital currencies and the utility of this rapidly growing new technology. Last year, OFAC announced an enforcement action against […]
The BitPay settlement shows that OFAC expects that companies providing digital currency services understand the sanctions risks associated with their activities and take steps necessary to mitigate those risks. In other words, the OFAC compliance obligations for digital payment service providers, such as BitPay, are no different than those of any other financial service provider. […]
This article suggests that by following the ransomware due diligence checklist set forth below, a ransomware victim who opts to pay the ransom can in the least mitigate the chances of a U.S. civil enforcement action or criminal prosecution, and perhaps even avoid U.S. government scrutiny altogether. Source: (26) A Ransomware OFAC Due Diligence Checklist | LinkedIn