On 7 January, an article from Baker Donelson refers to advisories on the regulatory considerations financial institutions should take into account when processing ransom payments.  This comes in the light of substantial increase in ransomware attacks during the COVID-19 pandemic and anticipate that they will continue in 2021. OFAC and FinCEN warn financial institutions and payment intermediaries of potential sanctions risks involved in making ransom payments as well as provide information on requirements for SAR under AML regulations.  After examining the situation, the firm says that the new advisories reinforce the importance of financial institutions doing tabletop exercises to simulate what to do in the event of a ransomware attack and/or how to respond when a suspicious transaction is identified involving a customer that may be paying a ransom.

If you would like to make a (polite) gesture and make a (very) modest contribution to my ongoing with my relocation, removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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