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    Home /  Insights /  Memos and Newsletters /  Memo
    S&C Memos

    FinCEN Updates Ransomware Advisory

    Updated Guidance Emphasizes Timely Reporting, Virtual Currencies, and Whole-of-Government Approach to Enforcement

    November 11, 2021 | min read |
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    On November 8, 2021, the United States Department of the Treasury Financial Crimes Enforcement Network (“FinCEN”) issued an updated version of its Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments, originally issued in the fall of 2020. Coming as part of a strengthened and more unified federal government focus on the ransomware threat, the Updated Advisory provides additional guidance to regulated institutions on how to detect potential ransomware payments and augments FinCEN’s call for institutions to report suspected ransomware transactions promptly. FinCEN released the Updated Advisory contemporaneously with a joint enforcement action against a ransomware group and shortly after the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) released new guidance concerning convertible virtual currencies (“CVCs”) and sanctions.

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