Since 2020, the number and sophistication of ransomware attacks have spiked, largely perpetuated by organized criminal groups in Russia and Eastern Europe. Against that backdrop lies the U.S. government’s position on economic sanctions implemented by the U.S. Treasury Department’s the Office of Foreign Assets Control (OFAC) – which have escalated since Russia’s attack on Ukraine – prohibiting U.S. persons from making payments directly or indirectly to any individual, entity, group or country that is the target of such sanctions. In a guest article, Greenberg Traurig shareholders Jena Valdetero, Kara Bombach and Kyle Freeny discuss today’s most prevalent types of ransomware attacks; considerations for whether to make the ransom payment; FinCEN and OFAC’s ransomware guidance; and the U.S. government’s mitigation efforts. For more on sanctions basics, see our three-part series: “How Sanctions Regimes Work” (Jun. 16, 2022); “Their Impact on Private Fund Investors and Investments” (Jun. 23, 2022); and “How to Comply With Them” (Jul. 7, 2022).