A Spotlight on Financial Crime
Stay on top of regional trends and novel criminal techniques so you can protect your business from financial crime.
Download Our Free Global Compliance ReportFrom October 31 to November 1, 2022, the International Counter Ransomware Initiative (CRI) launched its second summit meeting to discuss the prevention of large-scale cyber attacks and money laundering via digital currencies. Present at the summit were representatives from 36 CRI partner countries, including the US, the UK, Singapore, Australia, and Brazil.
In June 2021, the Financial Crimes Enforcement Network (FinCEN) highlighted its concern about ransomware attacks in its first US government-wide list of national priorities for anti-money laundering and counter-terrorism financing (AML/CFT). Launched in October 2021, the CRI was part of President Biden’s plan to act on this priority and safeguard digital networks worldwide.
Through 2022 the CRI has focused on increasing the resilience of all CRI partners, disrupting cyber criminals, countering illicit finance, building private sector partnerships, and cooperating globally to address the challenge. In 2023, the CRI plans to continue this work by taking the following actions:
Following the summit, the CRI partners issued a joint statement reaffirming their commitment to disrupting ransomware attacks and protecting their citizens from cybercriminals. To meet these goals, the partners listed their intention to:
Also on November 1, FinCEN published a Financial Trend Analysis report on ransomware trends in Banking Secrecy Act (BSA) data between July 2021 and December 2021. Pursuant to section 6206 of the Anti-Money Laundering Act of 2020 (AMLA), which requires FinCEN to publish threat patterns and trend information derived from BSA filings, the report highlights that ransomware continues to pose a significant threat to US critical infrastructure sectors, businesses, and the public.
The most notable findings in the report include:
According to the report’s press release, FinCEN Acting Director Himamauli Das said, “[The findings] underscore the importance of BSA filings, which allow us to uncover trends and patterns in support of whole-of-government efforts to prevent and combat ransomware attacks. Financial institutions play a critical role in helping to protect the United States from ransomware-related threats simply by fulfilling their BSA compliance obligations.”
When filling out suspicious activity reports (SARs) related to ransomware, FinCEN reminds compliance teams to include the key term: “CYBERFIN-2021-A004” and select SAR field 42 (Cyber Event).
To mitigate against the threat of ransomware, firms must boost their cyber defenses and practice good cyber hygiene. Strong cybersecurity controls should be in place alongside business continuity and resiliency plans. Firms should also familiarize themselves with the ransomware trends and typologies identified by FinCEN in its November 2021 advisory, including:
The typologies identified by FinCEN should be built into firms’ controls. Finally, compliance staff should ensure they are aware of the sanctions risks of processing payments on behalf of victims, as highlighted by OFAC in its updated September 2021 advisory.
Stay on top of regional trends and novel criminal techniques so you can protect your business from financial crime.A Spotlight on Financial Crime
Originally published 04 November 2022, updated 04 November 2022
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