Good Practice

Ransomware – is your compliance program ready?

Issue 17.
October 2021

Author
Evan AbramsMeredith Rathbone
+ About author

Evan Abrams is an Associate in the Washington, DC office of Steptoe. www.steptoe.com

Meredith Rathbone is a Partner at Steptoe. She is based in the firm’s London and DC offices. mrathbone@steptoe.com

STEPTOE: OUTSIDE COUNSEL

Every company dreads becoming the victim of a ransomware attack. Well-prepared companies will have a plan and spring into action. OFAC’s recent guidance has underscored why compliance personnel for companies – and their insurers, financial institutions, and other “facilitators” – need to ensure that sanctions compliance is adequately integrated into their ransomware action plans.

Last month, the Office of Foreign Assets Control (“OFAC”) updated its prior (2020) ad...

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