On June 30, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued its first-ever Anti-Money Laundering and Countering the Financing of Terrorism National Priorities (the “Priorities”). FinCEN was required to do this by the Anti-Money Laundering Act of 2020 (“AMLA”), enacted on January 1, 2021, as part of the National Defense Authorization Act of 2021. FinCEN
Ransonware Payments
OFAC and FinCEN Release Advisories on Risks of Ransomware Payments
On October 1, 2020, the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) each released advisories (the OFAC Advisory and the FinCEN Advisory) addressing financial crime-related risks associated with ransomware and ransomware payments. The OFAC Advisory focuses on the risk that ransomware attacks or payments may involve sanctioned persons…