SSS · Data Breach & Cyber Incident Response

Is paying a ransom unlawful?

A decision to pay carries serious risks in terms of sanctions lists, anti-money-laundering legislation, and insurance policy terms. The decision should not be taken alone; it should be docu…

Updated · July 20261 min readCategory · Data Breach & Cyber Incident Response
Short answer

A decision to pay carries serious risks in terms of sanctions lists, anti-money-laundering legislation, and insurance policy terms. The decision should not be taken alone; it should be documented with a legal assessment.

A decision to pay carries serious risks in terms of sanctions lists, anti-money-laundering legislation, and insurance policy terms. The decision should not be taken alone; it should be documented with a legal assessment.

Before any payment is even discussed, the threat actor should be screened against sanctions lists — a transfer to a listed entity can itself be an offence, regardless of the ransom question. Involve law enforcement early and route the decision through counsel and your insurer together; a unilateral payment is the riskiest path.

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This content is for general information only and does not constitute legal advice. Please contact our team for an assessment of your specific circumstances.
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