The “Highlights” — To Russia, With Crypto
The Financial Crimes Enforcement Network (“FinCEN”) issued on November 1 a Financial Trend Analysis regarding ransomware-related Bank Secrecy Act (“BSA”) filings during the second half of 2021 (the “Report”). This publication follows up on a similar ransomware trend analysis issued by FinCEN regarding the first half of 2021, on which we blogged here.
In the most recent analysis, FinCEN found that both the number of ransomware-related Suspicious Activity Reports (“SAR”) filed, and the dollar amounts at issue, nearly tripled from 2020 to 2021. The notable takeaways from the Report include:
- Ransomware-related SARs were the highest ever in 2021 (both in number of SARs and in dollar amounts of activity reported).
- Ransomware-related SARs reported amounts totaling almost $1.2 billion in 2021.
- Approximately 75% of ransomware-related incidents between June 2021 and December 2021 were connected to Russia-related ransomware variants.
The Report, which stated that the majority of these ransomware payments were made in Bitcoin, serves as a particular reminder to cryptocurrency exchanges of their role in both identifying and reporting ransomware-related transactions facilitated through their platforms. The Report stresses that SAR filings play an essential role in helping FinCEN identify ransomware trends.