On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” While this advisory explicitly supersedes OFAC’s previous ransomware advisory from October 2020, it does not fundamentally alter OFAC’s approach towards ransom payments. Like the prior guidance, OFAC’s […]