by Luke Dembosky, Avi Gesser, Satish Kini, Aseel Rabie, and HJ Brehmer
On November 8, 2021, the U.S. Department of the Treasury (“Treasury”) announced a new set of sanctions against criminal ransomware actors, the virtual currency exchange Chatex and three companies providing material support and assistance to Chatex. By designating these entities, which have direct ties with the previously sanctioned SUEX OTC, S.R.O. (“SUEX”), Treasury is suggesting that it will continue to use all tools available to identify and take action against those involved in facilitating ransomware payments.