The scenario is a sad one, but all too frequent: you come to the
office and learn that all your company's computers and servers
are encrypted. You don't know if your clients' data is
safe. The only image your computers will display is a mocking
ransom note, directing you to immediately pay thousands of dollars,
otherwise the attacker will delete your data. To add insult to
injury, you must pay in Bitcoin, a virtual currency made famous for
its use as tender in Dark Web drug transactions and underground
arms sales. So you ask your IT department to get some Bitcoin and
make the payment. What could be worse?
For one thing, your payment may run afoul of U.S. anti-money
laundering laws. In particular, any company that makes such a
payment risks being categorized as a "money service
business" (MSB) under the Bank Secrecy Act (BSA) and
corresponding U.S. Treasury regulations. MSBs are treated as
financial institutions, like banks, under the BSA. A company that
qualifies
