Regulatory Alerts2016-10-25 | FinCEN Advisory - FIN-2016-A005Added
Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime (FinCEN Advisory - FIN-2016-A005)
This advisory clarifies that existing Bank Secrecy Act requirements mandate Suspicious Activity Report filings for cyber-events if the institution knows, suspects, or has reason to suspect the event was intended to facilitate a transaction aggregating $5,000 or more in funds or assets. It requires financial institutions to include relevant cyber-related information, such as IP addresses with timestamps and device identifiers, within SAR narratives or attached CSV files. The document further encourages internal collaboration between BSA/AML and cybersecurity units and promotes voluntary information sharing among institutions under the Section 314(b) safe harbor.