What Cyber Insurers Should Know About the Federal Ransomware Advisories
As the COVID-19 pandemic and the switch to remote work have highlighted cyber risks and drawn attention to the various methods cyber attackers are using, ransomware has continued to steal the spotlight.
Ransomware is a type of malicious software that is designed to block access to a computer system until a ransom is paid, and these attacks have increased in severity and frequency in the past year alone.
In October, 2020, the U.S. Treasury Department issued a warning that individuals or businesses, including cyber insurers, that help facilitate ransomware payments could be violating anti-money laundering and sanctions regulations.
WilmerHale
On April 29, 2021, the US Department of the Treasury s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies.
Arnold & Porter
On April 29, 2021, the departments of Justice, Commerce and Treasury announced that they had reached a global resolution with SAP SE (SAP), a multinational software company based in Germany.
Baker Botts
In a first of its kind, on April 29, the U.S. Department of Justice announced1 the entry into a Non-Prosecution Agreement.
Arnold & Porter
The US government is increasingly prioritizing trade enforcement of the tech industry s global data services. This is reflected in SAP SE s global resolution.
Polotsk Steklovolokno OAO
Wind down transactions in excess of $50,000 must be reported to the U.S. Department of State no later than 30 days after executing the transaction.
Under the previous General License 2G and its predecessors, most business with these companies was authorized by OFAC. Given this change, and the prominence of these state-owned entities in Belarus’s economy, U.S. companies that do business in Belarus should carefully review their business relationships to ensure that any dealings involving these nine entities and their subsidiaries are wound down prior to June 3, 2021.
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Last week, three U.S. agencies – the Office of Foreign Assets Control (“OFAC”), the U.S. Department of Commerce (“Commerce”), and the U.S. Department of Justice (“DOJ”) – announced the global resolution of apparent U.S. sanctions violations by SAP SE (“SAP”), a German software company.
The settlement agreements with OFAC and Commerce, and the non-prosecution agreement with DOJ, highlight sanctions risks specific to the cloud and software industry and provide insight on the U.S. government’s compliance program expectations for companies that sell software and services online.
Daily Times
May 6, 2021
The June deadline for our review of Financial Action Task Force (FATF) of our remaining actions items is approaching and there are still many key areas that the authorities need to pay attention to come out of grey list we placed in June 2018. The general perception in Pakistan is that FATF’s action against us of keeping in the grey list is politically motivated under the influence of the United States of America (USA), India, France and some other members. The debate and discussion around this narrative is more emotional than based on objective evaluation of our persistent failure to meet all the action items agreed in June 2018. Now, with the new government of democrats in USA, there is hope in official quarters that in June 2021, we will be out of grey list.