For executive leaders and General council, the release this week by the US treasury of their advisory on Ransomware payments should be read.

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For executive leaders and General council, the release this week by the US treasury of their advisory on Ransomware payments should be read.

In my view it has regulatory and compliance implications which should be considered by US and EU companies when it comes to making ransomware payments to listed people, organisations and jurisdictions.

Attention should be made to its impact outside of the US. Payments in dollars, payments which may involve US payments Infrastructure and US subsidiaries are all considerations when assessing OFAC liability.

Ted Dziekanowski Jason Spezzano Brian McCarthy

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