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A great report that highlights in my view the whole of government approach being taken by the US over cybersecurity.
The US Department of Treasure (DoT) specifically the Financial Crimes unit (FinCEN) has been busy focusing on cybersecurity and ransomware payments. Reviewing Suspicious Activity Reports (SARs) filed by US financial institutions between January 1st 2011 and June 30th 2021. Accounting for what it believes is around $5.2 Billion paid to address the top 10 most common ransomware variants and highlighting $590 million being paid in H1 2021, from over 600 SARs alone. The DoT announced a number of actions over the past 2 weeks to strengthen ransomware payment oversight and reporting under OFAC. Including sanctioning the SUEX crypto exchange for its part in facilitating transactions for ransomware actors.
These actions highlight the treasury’s role as part of the whole of government approach that is starting to come out of Federal Government on cybersecurity and cyber risk management. This includes recent legislative announcements on FISMA (2021) and the Cyber Incident Reporting Bill. DFARS 252.204-7012, 7019 and 7020 regulations are in place for DoD contractors, allowing for the oversight and assurance of compliance to NIST SP 800-171 cybersecurity standards. The Department of Justice announced recently that it intends to progress the use of the False Claims Act (FCA). Targeting companies that have failed to implement appropriate cybersecurity standards and reporting as required under Federal regulation that includes existing FISMA (2014) and DFARS.
Recent announcements of US legislative changes and enforcement of current regulation will impact countries outside US. So buyer beware.
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