Remember when terrorism and ransomware attacks were topping global lists of stuff to be seriously concerned about? Seems a faint distant memory in the current 2020 climate. Many of us might gladly trade the ‘now’ for the ‘then’, in a weird kind of way.
In reality, those things remain a danger—only the news cycle has moved on, and the public frame of reference with it. You can only give your attention to and worry about so many things at once, right?
Well, prepare to up your bandwidth for things that give you the heebie jeebies, because ransomware, OFAC and sanctions breaches just combined in new and mildly terrifying ways.
Get Hit With Ransomware & You Might Get Hit With an OFAC Fine.
Sounds delightful, doesn’t it?
Imagine. You log into your laptop one morning to find a screen invaded by an immovable ransomware demand for payment, before you’re kindly reacquainted with the entirety of your digital life, that your livelihood likely depends on—not cool. What do you do? If the ransom demand won’t bankrupt you, do you pay it?
Ok, let’s suppose you do—congratulations, you just made yourself eligible for a potentially expensive phone call from the US Treasury’s Office of Foreign Assets Control (OFAC).
OFAC indeed. What do they want with you? They might just want to rock your world further by adding a heavy fine to the ransomware losses you just made through no fault of your own.
“On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued an advisory to alert companies that might pay ransomware attackers of the potential sanctions risks for facilitating ransomware payments.” Source: Security Privacy and the Law
In other words, the simple act of trying to regain access to the data you just had held ransom, could make you complicit in financing nefarious activities by persons under sanction and under the watchful eye of OFAC.
If Your Clients Wannacry, You Might Wannacry With Them.
The scenario doesn’t get much prettier…
In July, The Jerusalem Post reported that “Ransomware attacks increased by some 72% over.” That’s a sizeable uptick, and one with simmering potential to trigger the mother of all sanctions-breach pandemics.
We’re not using the word lightly here—even if you’re prudent enough to “consult with a counsel versed in OFAC compliance”, as suggested by the very advisory published by, It’s possible any one of your clients or business associates paid up in a panic after being hit with ransomware.
That being the case, you’re now a potential target for OFAC for potentially transacting with an organisation that has themselves been caught “facilitating ransomware payments”, as the Foaley Hoag journal, Security Privacy and the Law, puts it.
Now imagine that at scale—that’s the sanctions pandemic potential we’re talking about that creates a clear need and urgency for locking down robust sanctions compliance processes in order to lock OFAC out of your affairs and keep your nose clean.
Creating a Culture of Compliance
This isn’t to stir up fear and panic—just because you’ve learned of the increased risk doesn’t mean you’re going to wake up to a fine tomorrow—though the increased risk is very real.
Ultimately, it’s about building sanctions compliance practices as an integral component of your company culture—one that should administer the right level of awareness and diligence as standard, across departments, through both HR and routine compliance practices practices.
All that takes time. We help mitigate the risk in the meantime, and we can help you do that very quickly while you work to build a more pervasive culture of compliance in your organisation in the longer term.
Book an ScreenAML demo with us, and we’ll show you how you can quickly and cost-effectively drive the kind of sanctions compliance assurance, virtually overnight, that will help safeguard against potential scrutiny from OFAC— should a business associate catch a bad case of the Wannacrys, and pay up, leaving you open.
To sooth the worry further and get more prepared, this Deolitte resource delivers useful information on how to build resilience against ransomware attacks, and how to respond in the short term, should you be unfortunate enough to get hit—thanks for reading.