FOLLOW US

Sun

August 23, 2026

Business October 19, 2020 5 mins read

Is it legal to pay ransomware ransoms?

Business ı By Jackie Allen

0 Comments

ransomware sanctions

Ransomware attacks have become more sophisticated and widespread, affecting almost everyone from large corporations, small and medium-sized businesses, government agencies, non-profit organizations, hospital systems to individual consumers. Once a computer network or system is infected by ransomware, cybercriminals encrypt the victim's files and demand a ransom in exchange for a decryption key. Victims often have no choice but to pay ransomware ransoms to regain access to their files. Is it legal to pay ransomware ransoms to hackers?

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an advisory regarding ransomware payments. There has been very little mention or analysis of the ‘Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This is surprising since the document questions the legality of paying ransomware ransoms.

According to the advisory, there are “sanctions risks associated with ransomware payments related to malicious cyber-enabled activities.”

This means that companies that help or facilitate ransomware ransoms to cybercriminals are at-risk of violating the OFAC regulations. This puts the victims of an attack, as well as, “financial institutions, cyber insurance firms, and companies involved in digital forensics and incident response,” in the crosshairs of possible US sanctions or at-risk of a “sanctions nexus.”

Background of Ransomware Attacks 

Ransomware is malicious software or malware which attacks a computer network to shut down access to the computer system and/or the data until a ransom is paid. Ransomware is usually spread through phishing emails or when a cybercriminal gets employee login information.

Cybercriminals target companies, institutions, and other online systems that people rely on to continue conducting business.

According to the Federal Bureau of Investigation's (FBI) 2018 and 2019 Internet Crime Reports, ransomware cases increased by 37%  and there was a “147 percent annual increase in associated losses" during those years.  And in 2020, ransomware attacks have also dramatically increased during the COVID-19 pandemic. 

Wanted by the US for Cybercrimes

OFAC maintains a Specially Designated Nationals and Blocked Persons List (SDN List), which details blocked persons, country, and regional embargos. This includes numerous cybercrime groups and parts of the world including, “Cuba, the Crimea region of Ukraine, Iran, North Korea, and Syria.” 

Since 2013, OFAC has designated many malicious cyber actors including those committing ransomware attacks, using its “cyber-related sanctions program and other sanctions programs.”

Examples include Russia-based and state-sponsored Evgeniy Mikhailovich Bogachev, who developed the Cryptolocker ransomware used to infect 117,000 computers in the United States between 2013 and 2016. Bogachev goes by the online monikers of “lucky12345” and “Slavik” and is wanted by the FBI. There is a $5 million reward for his capture.

The SamSam ransomware started being used in 2015 to 2018 to target many governmental institutions, large cities, like Atlanta, Georgia, and big companies.  OFAC sanctioned two Iranian nationals suspected of working on behalf of Iran for providing material support of ransomware attacks.

The North Korean Lazarus Group also known as the Hidden Cobra uses the WannaCry 2.0 ransomware. They may employ as many as 6,000 hackers and have been linked to 300,000 computer attacks in 150 countries. They are also suspected of the 2020 attacks targeting the cryptocurrency vertical. 

Russian state-sponsored Evil Corp is a “cybercriminal organization, which used the Dridex malware to infect computers and harvest login credentials from hundreds of banks and financial institutions in over 40 countries, causing more than $100 million in thefts.”

The FBI is offering a $5 million reward for information to locate Evil Corp and their leader, Russian-based  Maksim V. Yakubets, who the government says went by the nicknames “aqua,” and “aquamo.”  OFAC has imposed sanctions on these actors and “will continue to impose, sanctions on these actors and others who materially assist, sponsor, or provide financial, material, or technological support for these activities.”

Also on the SDN list are 5 China-based international hackers known as Apt41. This hacking group is allegedly responsible for computer crimes including intellectual property  (IP) theft, ransomware attacks, and crypto-jacking that impacted over 100 companies, organizations, and individuals in the United States and other countries.

Last month, the U.S. government filed charges against seven international hackers who are suspected to be members of Apt41. Two of the defendants are citizens of  Malaysia and five were citizens of the People’s Republic of China (PRC), where they currently reside. They are also suspected to be connected to the Chinese Ministry of State Security. 

Facilitating ransomware ransoms may violate OFAC regulations 

This advisory highlights OFAC’s designations of malicious cyber actors and those who facilitate ransomware transactions under its cyber-related sanctions program.

Through the International Emergency Economic Powers Act (IEEPA) or the Trading with the Enemy Act (TWEA), U.S. citizens are prohibited from engaging in transactions, with individuals or entities on OFAC’s SDN list.

Sanctions compliance programs of any company that is attacked by ransomware should consider the possibility that ransomware payments may involve a person on the SDN list or an embargoed jurisdiction.

The advisory strongly suggests any company paying ransomware demands or any entity facilitating a ransomware ransoms on their behalf should consider their obligations under the Financial Crimes Enforcement Network (FinCEN) regulations. 

“OFAC will also consider a company’s self-initiated, timely, and complete report of a ransomware attack to law enforcement to be a significant mitigating factor in determining an appropriate enforcement outcome if the situation is later determined to have a sanctions nexus.” the advisory recommends. 

----------------------------------------

Have a story you want USA Herald to cover? Submit a tip here and if we think it's newsworthy, we'll follow up on it.

Want to contribute a story? We also accept article submissions – check out our writer's guidelines here.

Previous Article

FTC sued Critical Resolution Mediation, another debt collection scam

Read More
3296 Posts

Jackie Allen

Jackie is a freelance journalist and technology geek. She worked as a telecom project director for AT&T and BellSouth. Before joining the USA Herald she has written books, articles, blogs and whitepapers. Her clients include Samsung and other technology companies.

Discussion

No comments yet. Be the first to join the discussion!

Don’t Miss It
America August 21, 2026
Publix Blueberry Recall Escalates to FDA’s Highest Danger Rating
By – Rihem Akkouche
Breaking News August 21, 2026
Tyler Duckworth, ‘The Challenge’ Champion, Dies…

 The two-time MTV winner had been in front of an…

By – Ramzi Salem
High Profile Court Cases August 21, 2026
Alex Jones’ $45M Punitive Award Cut…

AUSTIN, Texas — The Texas Third Court of Appeals cut…

By – Michallie Harrison
High Profile Court Cases August 21, 2026
Pawleys Island School Closes After Sex-Offender…

PAWLEYS ISLAND, S.C. — Pawleys Island Christian Academy has closed…

By – Michallie Harrison
America August 21, 2026
Eric Swalwell Faces FBI Search as…

WASHINGTON — Former congressman Eric Swalwell is facing an escalation…

By – Jackie Allen
High Profile Court Cases August 20, 2026
Austin Metcalf’s Racist History Kept From…

MCKINNEY, Texas — Jurors who rejected Karmelo Anthony’s self-defense claim…

By – Michallie Harrison
America August 20, 2026
Ilja Dragunov Departs From WWE, Closing…

A wrestler once billed as “the Mad Dragon” has slipped…

By – Rihem Akkouche
America August 20, 2026
Ilja Dragunov Departs From WWE, Closing…

A wrestler once billed as “the Mad Dragon” has slipped…

By – Rihem Akkouche
America August 20, 2026
Comcast $117.5M Settlement Clears Final Hurdle…

A data breach that touched more than 31 million lives…

By – Rihem Akkouche
America August 20, 2026
Mitsubishi Electric to Acquire PCI Energy…

Mitsubishi Electric Corp. just planted a much bigger flag in…

By – Rihem Akkouche
America August 20, 2026
ISIS New York Capitol Attack Plot…

A plan authorities describe as both deliberate and deeply dangerous…

By – Rihem Akkouche
America August 20, 2026
KKR’s $9B UGI Bid Headlines a…

Wall Street’s rumor mill never really sleeps, but this week…

By – Rihem Akkouche
America August 20, 2026
Slayer’s Law Blocks Nick Reiner From…

The Slayer’s Law more commonly called a “slayer statute,” has…

By – Jackie Allen
America August 20, 2026
Slayer’s Law Blocks Nick Reiner From…

The Slayer’s Law more commonly called a “slayer statute,” has…

By – Jackie Allen
America August 20, 2026
Bitcoin Twins See Bitcoin’s $65,000 Level…

The Bitcoin Twins, Cameron and Tyler Winklevoss, are once again…

By – Jackie Allen
America August 19, 2026
Hayden Panettiere Death Investigation Heats Up…

 Police Seek Answers in Panettiere’s Final Hours A Death Investigation…

By – Jackie Allen
America August 18, 2026
Hayden Panettiere Remembered for her Acting…

Hayden Panettiere, the former child star who became internationally known…

By – Jackie Allen
America August 18, 2026
Penn State Cocaine Ring Used Pledges,…

HARRISBURG, Pa. — Fourteen people face charges in an alleged…

By – Michallie Harrison
America August 18, 2026
Homewrecker Lawsuit Puts North Carolina’s Rare…

Former Sen. Kyrsten Sinema is at the center of a…

By – Jackie Allen
America August 20, 2026
Robin Williams’ Children Reactivate His Instagram…

Inside This Report Zak, Zelda, and Cody Williams have relaunched…

By – Samuel Lopez
America August 19, 2026
Christian Metal Band Demon Hunter Declares…

INSIDE THIS REPORT Christian metal band Demon Hunter has sued…

By – Samuel Lopez
America August 19, 2026
Judge Removed After Saying Jury “Got…

INSIDE THIS REPORT A visiting judge removed Judge John Roach…

By – Samuel Lopez
America August 19, 2026
Did the Government Just Admit It…

INSIDE THIS REPORT Avi Loeb says government sources asked him…

By – Samuel Lopez
America August 19, 2026
Eight Years After Elon Musk Shot…

Key Takeaways Elon Musk’s Tesla Roadster has been traveling through…

By – Samuel Lopez
America August 19, 2026
A Near-Total “Blood Moon” Will Light…

Key Facts A deep partial lunar eclipse will be visible…

By – Samuel Lopez
America August 16, 2026
Perez Hilton’s Mother Seeks Temporary Custody…

By Samuel López | USA Herald Perez Hilton’s family has…

By – Samuel Lopez
America August 13, 2026
Taylor Farms Jalapeño Recall Salmonella Scare…

A single shipment of peppers has set off a chain…

By – Rihem Akkouche
America August 12, 2026
Heat Dome Brings Dangerous Temperatures Across…

A powerful Heat dome is expanding across the United States,…

By – Jackie Allen
America August 8, 2026
Joe Biden: Hunter Says the Prostate…

Former President Joe Biden is experiencing a worsening battle with…

By – Jackie Allen
America August 1, 2026
Stormed the Border: Spain Says 25,000…

CEUTA, Spain (AP) — Spanish authorities say thousands of migrants…

By – Jackie Allen
Breaking News July 29, 2026
Trump Ends Medicare Part D Subsidy,…

The Trump administration is ending a Medicare Part D subsidy…

By – Michallie Harrison
America August 17, 2026
Von Miller Cowboys Contract Brings Future…

Some homecomings happen quietly. This one came with a social…

By – Rihem Akkouche
America August 14, 2026
White House Denies Role in Josh…

LOS ANGELES — The White House is denying any role…

By – Michallie Harrison
America August 13, 2026
Prichard Colon Death: Once-Unbeaten Boxer Dies…

Prichard Colon never threw another punch after that October night…

By – Rihem Akkouche
America August 13, 2026
Tiger Woods and Nike: 27-Year Partnership…

Tiger Woods built one of the most lucrative athlete-brand partnerships…

By – Jackie Allen
America August 12, 2026
209 Triple-Doubles, Two Offers Declined: Russell…

There were two NBA teams ready to hand Russell Westbrook…

By – Rihem Akkouche
America August 11, 2026
Part 2. Archbald Faces Big Expansion…

In Archbald, Pennsylvania, a community of roughly 7,000 residents, the…

By – Jackie Allen

No posts found.

No posts found.

Signup for the USA Herald
exclusive Newsletter