FinCEN Issues BSA Cyber-Event Advisory

On October 25th the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2016-A005 regarding cyber-events and cyber-related crimes.  The 9 page advisory explains Bank Secrecy Act (BSA) responsibilities related to cyber-events and cyber-related crimes including:

  • Reporting cyber-enabled crime and cyber-events through Suspicious Activity Reports (SARs);
  • Providing relevant and available cyber-related information (Internet Protocol (IP) addresses with timestamps, virtual-wallet information, device identifiers) in SARs;
  • Collaborating between BSA/Anti-Money Laundering (AML) and in-house cyber security divisions to identify suspicious activity; and
  • Sharing information, including cyber-related information, among financial institutions to protect against and report money laundering, terrorism financing, and cyber-enabled crime.

The advisory also provides examples of situations where cyber-events require SAR reporting, which you can view here.


  • 218-790-1086

John Zasada is a principal with CLA and leads the firm’s financial institution regulatory compliance practice. He assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, training staff on regulations, and performing website compliance assessments. In addition, John is a frequent speaker at industry conferences and state associations. Prior to joining CLA, he served as managing director at a top-10 accounting firm and as the compliance officer of a large financial institution, where he developed and implemented its first regulatory compliance program.

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