Clifford Chance

FinCEN flexes new expertise in clear warning to companies broadly involved in processing ransomware payments

October 25, 2021

The latest study on ransomware from the US Treasury's Financial Crimes Enforcement Network reflects the US Government's continuing coordinated focus on cybercrime, and ransomware in particular. The study shows increasing ability by FinCEN, and potentially other parts of government, to chart the flow of ransomware payments, particularly in bitcoin, in traditional "follow the money" style, and to identify the most frequently used exchanges and services ransomware actors use to launder their proceeds. According to the study, victims predominantly sourced payment funds from U.S.-registered exchanges and extortionists use foreign centralized convertible virtual currency exchanges as their "preferred cash-out points."

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