A recent advisory notice issued by the Office of Foreign Assets Control (OFAC) won’t necessarily put more direct pressure on organizations to ascertain the identities of bad actors behind ransomware attacks. But it could force legal departments and the companies they serve to overcome their reluctance toward voluntarily approaching the FBI or other law enforcement agencies in the wake of a cyberattack. 

While the advisory did reaffirm the existence of sanctions facing both businesses that choose to pay a ransom to a blocked person/embargoed jurisdiction, or a provider that helps facilitate such a transaction, OFAC’s latest bulletin isn’t necessarily bringing anything new to the table. “I do not believe that anything really has changed. … When I think about my team and the way that we are responding to ransomware matters, nothing really has changed,” said Ted Kobus, chair of the digital assets and data management group at Baker & Hostetler.

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