The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued an updated advisory, in follow-up to the initial advisory issued in October 2020, to highlight the sanctions risks associated with ransomware payments in connection with malicious cyber-enabled activities and the proactive steps companies can take to mitigate such risks, including actions that OFAC would consider to be “mitigating factors” in any related enforcement action.

The advisory includes cryptocurrency exchanges, and notes the possible sanctions which companies could face if found to be in violation of OFAC guidelines.

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