Tag Archives: John Barker

Virtual Currency Platforms and Ransomware Attacks: OFAC Advisories Highlight Increasing Overlap of Sanctions and Cybersecurity Risks Associated with Virtual Currency Platforms and Ransomware Attacks (Part II of II)

by John Barker, Ronald Lee, Soo-Mi Rhee, Tal Machnes, and Christine Choi 

This is part II of a two-part post. For Part I, which outlines two OFAC advisory opinions on US sanction risks associated with cyber related activities, including virtual currency platforms, click here. 

Focus on Virtual Currency Platforms

OFAC’s increased focus on cybersecurity, generally, has also put a spotlight on the sanctions risks specific to the virtual currency industry. Indeed, concurrent with the release of its September 2021 Updated Advisory, OFAC added SUEX OTC, S.R.O. (SUEX), a Russian virtual currency exchange, to the SDN List for facilitating financial transactions for ransomware actors—the first such designation of a virtual currency exchange. According to Treasury, over 40% of SUEX’s known transactions were associated with illicit actors, and the exchange facilitated transactions involving at least eight ransomware variants. In designating SUEX, Treasury observed that the virtual currency sector plays a “critical role” in sanctions compliance.[1]

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Virtual Currency Platforms and Ransomware Attacks: OFAC Advisories Highlight Increasing Overlap of Sanctions and Cybersecurity Risks Associated with Virtual Currency Platforms and Ransomware Attacks (Part I of II)

by John Barker, Ronald Lee, Soo-Mi Rhee, Tal Machnes, and Christine Choi 

This is part I of a two-part post. For Part II, click here.

In the last few months, the Office of Foreign Assets Control (OFAC) of the US Department of Treasury (Treasury) has issued two advisories that highlight the heightened US sanctions risk associated with cyber related activities, including ransomware attacks and the virtual currency platforms that ransomware payers often use to facilitate payments.

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