OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory comments strongly discouraging companies from making ransomware payments and suggests proactive steps for mitigating ransomware risks, including actions that OFAC would consider to be “mitigating factors” in any related enforcement action.