On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated advisory on potential sanctions risks for companies that facilitate ransomware payments in response to cyberattacks, guidance on preventative measures companies can implement to mitigate such risks, and criteria that OFAC will consider as mitigating factors in any potential enforcement action. OFAC also announced that it has added SUEX OTC, S.R.O. (“SUEX”), a Russian virtual currency exchange, to its Specially Designated Nationals and Blocked Persons List (the “SDN List”), as a result of its role in facilitating ransomware payments. This represents OFAC’s first-ever designation of a virtual currency exchange.

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Photo of Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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Photo of Laura Foggan Laura Foggan

Laura Foggan is a partner in Crowell & Moring’s Washington, D.C. office, and chair of the firm’s Insurance/Reinsurance Group. She has been described by LawDragon 500 Magazine as “one of the most successful advocates for the insurance industry to ever practice.” Laura was…

Laura Foggan is a partner in Crowell & Moring’s Washington, D.C. office, and chair of the firm’s Insurance/Reinsurance Group. She has been described by LawDragon 500 Magazine as “one of the most successful advocates for the insurance industry to ever practice.” Laura was recently recognized as a Global Elite Thought Leader for Insurance & Reinsurance by Who’s Who Legal (2019), who praised her as a “dynamic and creative thinker” who has “very high standards and delivers superior work.” She is a Chambers-ranked Band 1 practitioner and included in the Best Lawyers in America directory, and consistently named one of Washington D.C.’s “Top 100 Lawyers” and “Top 50 Women Lawyers” and a “Super Lawyer” for Insurance Coverage by Super Lawyers Magazine. Laura represents clients in a variety of litigation and counseling matters.

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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Photo of Jeffrey L. Poston Jeffrey L. Poston

Jeff Poston is a partner in Crowell & Moring’s Washington, D.C. office, where he serves as co-chair of the firm’s Chambers USA-ranked Privacy & Cybersecurity Group and is a member of the Litigation Group. A seasoned trial lawyer with more than 25 years…

Jeff Poston is a partner in Crowell & Moring’s Washington, D.C. office, where he serves as co-chair of the firm’s Chambers USA-ranked Privacy & Cybersecurity Group and is a member of the Litigation Group. A seasoned trial lawyer with more than 25 years of experience leading investigations and litigation for corporate clients, Jeff counsels and defends clients in complex data protection matters involving class-actions and regulatory enforcement actions, as well as commercial disputes. Jeff also counsels businesses on both domestic and international privacy compliance matters, including the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).

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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice…

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations. He is experienced in providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws that can arise from the interaction between extraterritorial impacts of U.S. regulations and third country “blocking” laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.

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Photo of Evan D. Wolff Evan D. Wolff

Evan D. Wolff is a partner in Crowell & Moring’s Washington, D.C. office, where he is co-chair of the firm’s Chambers USA-ranked Privacy & Cybersecurity Group and a member of the Government Contracts Group. Evan has a national reputation for his deep technical…

Evan D. Wolff is a partner in Crowell & Moring’s Washington, D.C. office, where he is co-chair of the firm’s Chambers USA-ranked Privacy & Cybersecurity Group and a member of the Government Contracts Group. Evan has a national reputation for his deep technical background and understanding of complex cybersecurity legal and policy issues. Calling upon his experiences as a scientist, program manager, and lawyer, Evan takes an innovative approach to developing blended legal, technical, and governance mechanisms to prepare companies with rapid and comprehensive responses to rapidly evolving cybersecurity risks and threats. Evan has conducted training and incident simulations, developed response plans, led privileged investigations, and advised on hundreds of data breaches where he works closely with forensic investigators. Evan also counsels businesses on both domestic and international privacy compliance matters, including the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA). He is also a Registered Practitioner under the Cybersecurity Maturity Model Certification (CMMC) framework.

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Photo of Maida Oringher Lerner Maida Oringher Lerner

Maida Lerner is senior counsel in Crowell & Moring’s Washington, D.C. office and a part of the firm’s Privacy & Cybersecurity, Government Contracts, and Environment & Natural Resources groups. Maida counsels a broad group of clients in a variety of sectors on cyber…

Maida Lerner is senior counsel in Crowell & Moring’s Washington, D.C. office and a part of the firm’s Privacy & Cybersecurity, Government Contracts, and Environment & Natural Resources groups. Maida counsels a broad group of clients in a variety of sectors on cyber and physical security compliance and risk management, homeland security, and administrative matters, including trade associations and companies in the pipeline, transportation, government contracts, education, health care, and manufacturing sectors.

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Photo of Anand Sithian Anand Sithian

Anand Sithian is a counsel in Crowell & Moring’s New York office. He is a member of the International Trade and the White Collar & Regulatory Enforcement groups. Anand advises clients on a variety of regulatory issues and investigations relating to anti-money laundering…

Anand Sithian is a counsel in Crowell & Moring’s New York office. He is a member of the International Trade and the White Collar & Regulatory Enforcement groups. Anand advises clients on a variety of regulatory issues and investigations relating to anti-money laundering (AML), the Bank Secrecy Act (BSA), U.S. economic sanctions, including those administered by the Office of Foreign Assets Control (OFAC), and asset forfeiture matters. Anand routinely counsels clients on the novel application of these laws and regulations to issues involving financial institutions, technology and social media, virtual currency and digital assets (including the seizure and forfeiture of virtual currencies), and the evolving cannabis industry.

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Photo of Matthew B. Welling Matthew B. Welling

Matthew B. Welling is a partner in Crowell & Moring’s Washington, D.C. office, where he practices in the firm’s Privacy & Cybersecurity and Energy groups. Matthew has a deep technical background that he leverages to represent clients in a wide range of counseling…

Matthew B. Welling is a partner in Crowell & Moring’s Washington, D.C. office, where he practices in the firm’s Privacy & Cybersecurity and Energy groups. Matthew has a deep technical background that he leverages to represent clients in a wide range of counseling and regulatory matters. His experience includes cybersecurity and privacy incident response, compliance reviews, risk assessments, and the development of corporate policies and procedures, such as incident response plans. Matthew has a diverse background in M&A and other corporate transactional issues, with specific recent experience with technology transactions, cybersecurity issues, and critical infrastructure project development.

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