> An investigation by the NCA is very unlikely to be commenced into a ransomware victim, or those involved in the facilitation of the victim’s payment, who have proactively engaged with the relevant bodies as set out in the mitigating factors above
i.e you’re not even going to be investigated unless you try to cover things up.
This is a solved problem, big companies with big legal departments make large ransomware payments every day. Big incident response companies have teams of negotiators to work through the process of paying, and to get the best possible price.
You could very well be making a payment to a sanctioned individual or country, or a terrorist organization etc.