In Short
The Situation: On April 15, 2021, the United States issued a new executive order and related directive imposing additional sanctions on Russia that target dealings in Russian sovereign debt, the technology and defense sectors of the Russian economy, and the Russian government and its agents.
The Result: Expanding on existing sanctions, the United States imposed focused restrictions on participating in certain ruble and non-ruble denominated bond and debt transactions with the Russian government, imposed blocking sanctions on several Russian technology companies, and laid the groundwork for future sanctions.
Looking Ahead: U.S. financial institutions and companies should carefully review ongoing or prospective dealings in Russian sovereign debt or targeted sectors of the Russian economy in order to ensure compliance with these new sanctions and to prepare themselves for potential additional prohibitions. A White House press release warned that additional technology and so
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Recently, the U.S. Treasury Department s Office of Foreign
Assets Control ( OFAC ) sanctioned various individuals
and entities connected to Russia s technology sector and also
expanded sanctions against dealings in Russian sovereign
debt. In addition to these immediate actions, President Biden
also issued a new Executive Order which will significantly expand
OFAC s authority to impose future sanctions against Russia.
Background
The White House published a Fact Sheet which explains the recent sanctions
actions were a response to Russian election interference and
cyber-attacks directed at the United States. A month prior to
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Recent ransomware attacks against U.S. critical infrastructure, which includes the energy sector’s production of oil and natural gas, and other sources of electricity and power, have shed a spotlight on the importance of staying updated on sector-specific techniques, tactics and procedures (“TTPs”), and preventative and remediation actions.
This Client Alert will: (1) provide a brief background on the nature and risks of ransomware on critical infrastructure; (2) discuss the current ransomware threat landscape; (3) note legal considerations companies should take into account when determining how to respond to ransomware attacks; (4) discuss recent calls for cybersecurity oversight; (5) provide an overview of recent public ransomware incidents; and (6) set forth potential steps companies can take to mitigate the risks of ransomware.
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By Jaclyn Jaeger2021-04-30T15:46:00+01:00
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) on Thursday announced a $34,329 settlement with MoneyGram Payment Systems for 359 apparent violations of multiple sanctions programs.
The 359 transactions totaled $105,627 in value and were processed on behalf of approximately 40 individuals on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), as well as two individuals who initiated transactions linked to Syria.
OFAC determined the case to be “non-egregious.”
The details: Over a three-year period from March 2013 to April 2016, MoneyGram provided money transfer services to inmates as allowed by the Department of Justice’s Federal Bureau of Prisons (BOP). However, OFAC noted, the company did not screen inmates against the SDN List between March 2013 and January 2015, believing this was not expected under the BOP program.