FinCEN Details Bank Secrecy Act Reporting Obligations for Cyber Events and Cyber-Related Crime

The Financial Crimes Enforcement Network ("FinCEN") advised firms on Bank Secrecy Act ("BSA") reporting obligations regarding cyber events and cyber-enabled crime.

FinCEN recommended that financial institutions:

  • report cyber-enabled crime and cyber events through Suspicious Activity Reports ("SARs"), especially those cyber events that put customer funds at risk;

  • include relevant and available cyber-related information (e.g., Internet Protocol ("IP") addresses with timestamps, virtual-wallet information, device identifiers) in SARs;

  • collaborate with BSA / Anti-Money Laundering units and in-house cybersecurity units in identifying suspicious activity; and

  • share information (including cyber-related information) with other financial institutions to guard against and report money laundering, terrorism financing and cyber-enabled crime.

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