In this article, we discuss today’s most prevalent types of ransomware attacks, considerations for whether to make the ransom payment, the Financial Crimes Enforcement Network (FinCEN) and Treasury’s Office of Foreign Asset Control’s (OFAC) ransomware guidance, and the U.S. government’s efforts in connection with these attacks.

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As part of a larger spending bill signed by President Biden on March 15, 2022, Congress passed the Cyber Incident Reporting for Critical Infrastructure Act (CIRA) to increase funding for the federal Cybersecurity and Critical Infrastructure Agency (CISA). CIRA requires companies considered to be in a “critical infrastructure” sector to notify CISA within 72 hours