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FinCEN updates ransomware red flags: BSA/AML and OFAC compliance impacts

By Jennifer Morrison, VP, Senior Risk Manager

Ransomware is a real and growing threat to credit unions and your members. On November 8, the Financial Crimes Enforcement Network (FinCEN) updated its year-old list of red flags raised by ransomware payments. This update was part of a coordinated effort with the Department of Justice against two foreign cyberthieves and the Baltic cryptocurrency exchanges they used to launder the funds. FinCEN’s update is timely and has an impact on your credit union’s BSA/AML compliance efforts, as well as on your Office of Foreign Assets Control (OFAC) compliance.

Today’s article discusses FinCEN’s advisory and includes guidance on how to help your credit union proactively improve your security safeguards:

  • Summary and background
  • Breaking down the SARs
  • Previous reminders and guidance from OFAC
  • Application for your credit union
  • Ransomware attacks continue to rise, financial institutions among primary targets
  • Tactics used by cybercriminals, tips for prevention
  • SAR filing for cyber events
  • New resources