On October 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published an Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime and an accompanying Frequently Asked Questions document. The Advisory aims to assist financial institutions in understanding their Bank Secrecy Act (“BSA”) obligations regarding cyber-events and cyber-enabled crime. While the advisory does not change any existing regulatory requirements, it offers guidance for financial institutions to better understand how to identify, report, and share information under the BSA.

Reporting on Cyber-Events -

In the Advisory, FinCEN defines a “cyber-event” as “an attempt to compromise or gain unauthorized electronic access to electronic systems, services, resources, or information.” Cyber-events may trigger mandatory or voluntary reporting of Suspicious Activity Reports (“SARs”).