FinCEN To Financial Institutions: Include Cyber Data In Suspicious Activity Reports (SARs)

Article by Jonathan Lopez, Courtney Linn, Aravind Swaminathan, Antony P. Kim and Jonathan Direnfeld

As new legislation aimed at facilitating greater cybersecurity information sharing between private industry and government takes effect (i.e., Cybersecurity Information Sharing Act), FinCEN Director Jennifer Shasky Calvery recently called for "financial institutions to include cyber-derived information (such as IP addresses on bitcoin wallet addresses) in suspicious activity reports."  Director Shasky Calvery's statement dovetails with the Federal Financial Institutions Examination Council (FFIEC)  Cybersecurity Assessment Tool (CAT) launched last year that we discussed previously, which lists "threat intelligence and collaboration" through information-sharing forums as one of five key "domains" for assessing cybersecurity preparedness.  Regulated entities should take stock of this shifting risk management and compliance landscape, and evaluate the need for changes