Exception Tracking Spreadsheet (TicklerTrax™)
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Treasury acts to counter ransomware
The Department of the Treasury on Tuesday announced a set of actions focused on disrupting criminal networks and virtual currency exchanges responsible for laundering ransoms, encouraging improved cyber security across the private sector, and increasing incident and ransomware payment reporting to U.S. government agencies, including both Treasury and law enforcement.
Tuesday's actions included OFAC's designation of SUEX OTC, S.R.O. (SUEX), a virtual currency exchange, for its part in facilitating financial transactions for ransomware actors. The designation was made under the authority of Executive Order 13694, for providing material support to the threat posed by criminal ransomware actors. As a result of yesterday’s designation, all property and interests in property of the designated target that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Additionally, any entities 50% or more owned by one or more designated persons are also blocked. In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action.
For identification information for Suex OTC, S.R.O., see the September 21, 2021, BankersOnline OFAC Update.
OFAC also released an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments. The Advisory emphasizes that the U.S. government continues to strongly discourage the payment of cyber ransom or extortion demands and recognizes the importance of cyber hygiene in preventing or mitigating such attacks. OFAC has also updated the Advisory to emphasize the importance of improving cybersecurity practices and reporting to, and cooperating with, appropriate U.S. government agencies in the event of a ransomware attack. Such reporting, as the Advisory notes, is essential for U.S. government agencies, including law enforcement, to understand and counter ransomware attacks and malicious cyber actors.