Ransomware Payments Become an Even Riskier Choice Amidst the Ever-Growing Sanctions List

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In February 2022, Executive Order 14024 highlighted that Russia’s invasion of Ukraine threatened not only Ukraine but also the national security and foreign policy of the United States. Pursuant to this executive order, and in the face of national security concerns, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has instituted extensive sanctions, including both economic and trade sanctions. Also, in response to the national security concerns, the Cybersecurity and Infrastructure Security Agency (CISA) issued a Shields Up notice, urging companies to bolster their cybersecurity to protect themselves against the threat of a cyberattack.

As the conflict between Russia and Ukraine continues, the threat of a cyberattack, specifically ransomware and NotPetya-style attacks, remains top of mind. However, as entities continue to bolster their cybersecurity and protect themselves against these attacks, they should be cognizant of the implications that OFAC sanctions may have in connection with such an attack.

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Faegre Drinker on Law and Technology Podcast: Russia, Cybersecurity & Government Contracting

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Russia’s invasion of Ukraine has created a host of challenges for the U.S. government to address, including the need to prepare for potential Russian cyberattacks and questions about how to handle Russian connections to supply chains and government contracts. In this episode of the Faegre Drinker on Law and Technology Podcast, host Jason G. Weiss sits down with Faegre Drinker partners Dana Pashkoff and Jessica Abrahams to unpack the thorny issues at the nexus of Russia, cybersecurity and U.S. government activity.

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U.S. Government Details Prolonged Cyber Scheme by Russian State Actors Targeting the Energy Sector

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Last month, the U.S. Cybersecurity and Infrastructure Security Agency (CISA), the Federal Bureau of Investigation (FBI), and the U.S. Department of Energy (DOE) issued a joint advisory providing “information on multiple intrusion campaigns conducted by state-sponsored Russian cyber actors” that targeted “U.S. and international Energy Sector organizations.” While CISA, the FBI, and DOE all responded to these campaigns “with appropriate action in and around the time they occurred,” the U.S. government determined that it was important to share information about the attacks “in order to highlight historical tactics, techniques, and procedures (TTPs) used by adversaries to target U.S. and international Energy Sector organizations.”

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Capping Cyber Casualties: Steps to Avoid Cyberattacks Flowing From Hostilities in Ukraine

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Recognizing that cyberattacks have already commenced and could spread beyond the Russian-Ukrainian battlefield, organizations can take several steps to protect themselves. They can recognize the risk. Then organizations can assess likely cyber threats and vulnerabilities, build resilience and take preventive actions, to avoid becoming another casualty in a conflict that already has too many.

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SEC Cyber Unit Brings Groundbreaking Data Breach Case

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The Securities and Exchange Commission (SEC) announced its most significant case ever filed against a respondent for one of the world’s largest data breaches. Albata, Inc., f/d/b/a Yahoo! Inc., (“Yahoo”) settled with the SEC to charges of violating Section 17(a)(2) and 17 (a)(3) of the Securities Act of 1933 (“Securities Act”), amongst other charges, and agreed to various remedies, including a $35 million penalty.

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