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
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.
By now, policyholder advocates have focused on the fact that, apart from virus and contamination exclusions, a key issue for the viability of any COVID-19 claim for business interruption or civil authority coverage – at least under widely-used policy language – will be whether the policy trigger of physical damage can met by a…