Financial Trend Analysis: Ransomware Trends in BSA Data, Jan-Jun 2021

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Fincen

2021-10-15

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

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                            F I N A N C I A L           T R E N D        A N A L Y S I S

                    Ransomware Trends in Bank Secrecy Act Data
                       Between January 2021 and June 2021

     This Financial Trend Analysis focuses on ransomware pattern and trend information identified in Bank
     Secrecy Act (BSA) data. This report is issued pursuant to Section 6206 of the Anti-Money Laundering
     Act of 2020 (AMLA) which requires the Financial Crimes Enforcement Network (FinCEN) to
     periodically publish threat pattern and trend information derived from financial institutions’
     Suspicious Activity Reports (SARs).1 FinCEN issued government-wide priorities for anti-money
     laundering and countering the financing of terrorism (AML/CFT) policy on 30 June 2021, which
     included cybercrime as a government-wide priority. FinCEN highlighted ransomware as a particularly
     acute cybercrime concern. The information contained in this report is relevant to the public, including
     a wide range of businesses, industries, and critical infrastructure sectors. The report also highlights
     the value of BSA information filed by regulated financial institutions.

Executive Summary: This Financial Trend Analysis is in response to the increase in number and
severity of ransomware attacks against U.S. critical infrastructure since late 2020. For example, in
May 2021, hackers used a ransomware attack to extort a multi-million dollar ransom, which also
disrupted the Colonial Pipeline and caused gasoline shortages. Other recent attacks have targeted
various sectors, including manufacturing, legal, insurance, health care, energy, education, and the
food supply chain in the United States and across the globe. As Treasury Secretary Janet L. Yellen
recently noted, “Ransomware and cyber-attacks are victimizing businesses large and small across
America and are a direct threat to our economy.”2

FinCEN analysis of ransomware-related SARs filed during the first half of 2021 indicates that
ransomware is an increasing threat to the U.S. financial sector, businesses, and the public. The
number of ransomware-related SARs filed monthly has grown rapidly, with 635 SARs filed and
458 transactions reported between 1 January 2021 and 30 June 2021 (“the review period”), up
30 percent from the total of 487 SARs filed for the entire 2020 calendar year.3 The total value of
suspicious activity reported in ransomware-related SARs during the first six months of 2021 was
$590 million, which exceeds the value reported for the entirety of 2020 ($416 million).

Trends represented in this report illustrate financial institutions’ identification and reporting of
ransomware events and may not reflect the actual dates associated with ransomware incidents.
FinCEN’s analysis of ransomware-related SARs highlights average ransomware payment amounts,
top ransomware variants, and insights from FinCEN’s blockchain analysis:

1.    The AMLA was enacted as Division F, §§ 6001-6511, of the William M. (Mac) Thornberry National Defense
      Authorization Act for Fiscal Year 2021, Pub. L. 116-283 (2021).
2.    “Treasury Takes Robust Actions to Counter Ransomware,” U.S. Department of the Treasury, 21 Sept. 2021,
      https://home.treasury.gov/news/press-releases/jy0364.
3.    The 635 SARs filed during the review period include 458 SARs reporting transactions that occurred in the same
      timeframe. The remaining 177 SARs report transactions that occurred prior to 2021.

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                            F I N A N C I A L           T R E N D       A N A L Y S I S

Average Monthly Suspicious Amount of Ransomware Transactions: According to data generated from
ransomware-related SARs, the mean average total monthly suspicious amount of ransomware
transactions was $66.4 million and the median average was $45 million. FinCEN identified bitcoin
(BTC) as the most common ransomware-related payment method in reported transactions.

Top Ransomware Variants: Ransomware actors develop their own versions of ransomware, known as
“variants,” and these versions are given new names based on a change to software or to denote a
particular threat actor behind the malware. FinCEN identified 68 ransomware variants reported in
SAR data for transactions during the review period. The most commonly reported variants were
REvil/Sodinokibi, Conti, DarkSide, Avaddon, and Phobos.

Insights from Blockchain Analysis: FinCEN identified and analyzed 177 unique convertible virtual
currency (CVC) wallet addresses used for ransomware-related payments associated with the 10
most commonly reported ransomware variants in SARs during the review period.4 Based on
blockchain analysis of identifiable transactions with the 177 CVC wallet addresses, FinCEN identified
approximately $5.2 billion in outgoing BTC transactions potentially tied to ransomware payments.

FinCEN Identified Ransomware Money Laundering Typologies: FinCEN identified several money
laundering typologies common among ransomware variants in 2021 including threat actors
increasingly requesting payments in Anonymity-enhanced Cryptocurrencies (AECs) and avoiding
reusing wallet addresses, “chain hopping” and cashing out at centralized exchanges, and using
mixing services and decentralized exchanges to convert proceeds.

     Scope and Methodology: FinCEN examined ransomware-related SARs filed between 1 January
     2021 and 30 June 2021 to determine trends. The full data set consisted of 635 SARs reporting $590
     million in suspicious activity. Of the 635 SARs filed during the review period, 458 report actual
     transactions that occurred during the review period worth $398 million. The remaining 177 SARs
     report transactions that occurred before 1 January 2021.5 FinCEN reviewed and verified each
     SAR to remove any suspicious activity amount unrelated to ransomware and to extract relevant
     indicators of compromise (IOCs).6 From this data, FinCEN identified the top 10 most common
     ransomware variants and analyzed their IOCs through commercially available analytics tools.
     This analysis allowed FinCEN to chart the flow of ransomware payments in BTC to identify which
     CVC exchanges and services ransomware actors used to launder their proceeds. USD figures
     cited in this analysis are based on the value of BTC when the transactions occurred. FinCEN
     also compared data gathered for 2021 to SAR data gathered in previous years in order to track
     ransomware trends. This data set consisted of 2,184 SARs reflecting $1.56 billion in suspicious
     activity filed between 1 January 2011 and 30 June 2021.

4.    CVC wallet addresses are alphanumeric public keys that store value and can be accessed using a password or “private
      key.” Wallets are software used to organize multiple wallet addresses and their associate private keys.
5.    The data in this report consists only of information received through BSA reporting and is not a complete
      representation of all ransomware attacks or payments during the review period.
6.    IOCs are signatures or artifacts observed on a network that likely indicate computer or network intrusion.

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                           F I N A N C I A L           T R E N D        A N A L Y S I S

                                              What is Ransomware?

     Ransomware is malicious software that encrypts a victim’s files and holds the data hostage until
     a ransom is paid. In the last two years, ransomware actors have shifted from a high-volume
     opportunistic approach to a more selective methodology in choosing victims, targeting larger
     enterprises, and demanding bigger payouts to maximize their return on investment. Some
     ransomware actors have diversified their revenue streams using a ransomware-as-a-service
     (RaaS) business model in which ransomware creators sell user-friendly ransomware kits on the
     Dark Web or outsource ransomware distribution to affiliates in exchange for a percentage of
     the ransom. This lowers the technical expertise needed to carry out an attack. The transition to
     remote and online work in response to COVID-19 has also exacerbated risks and vulnerabilities
     of businesses to cyber attacks such as ransomware. Attacks on small municipalities and
     healthcare organizations have also increased, typically due to perceived weaker security
     controls and higher propensity of these victims to pay the ransom because of the criticality of
     their services, particularly during a global health pandemic. Additionally, since at least late
     2019, ransomware groups have adopted new extortion tactics to maximize revenue and create
     an additional incentive for victims to pay. In one such tactic, known as “double extortion,”
     ransomware operators exfiltrate massive amounts of a victim’s data encrypting it and then
     threaten to publish the stolen data if ransom demands are not met.7 Lastly, ransomware
     attackers are finding new ways to obfuscate their identities by requesting payment in AECs.8

Ransomware Filings in First Six Months of 2021 Exceed 2020 Total
The total U.S. dollar value for ransomware-related transactions reported in SARs filed during
the review period exceeds that of any previous year since 2011. In the first six months of 2021,
FinCEN identified $590 million in ransomware-related SARs, a 42 percent increase compared to a
total of $416 million for all of 2020 (see Figures 1 and 2).9 10 If current trends continue, SARs filed
in 2021 are projected to have a higher ransomware-related transaction value than SARs filed in the
previous 10 years combined, which would represent a continuing trend of substantial increases
in reported year-over-year ransomware activity. This trend potentially reflects the increasing
overall prevalence of ransomware-related incidents as well as improved detection and reporting
of incidents by covered financial institutions, which may also be related to increased awareness of
reporting obligations pertaining to ransomware and willingness to report.

7.  “Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments,” FinCEN Advisory
    #FIN-2020-A006, 1 Oct. 2020, https://www.fincen.gov/sites/default/files/advisory/2020-10-01/Advisory Ransomware
    FINAL 508.pdf.
8. As noted in FinCEN’s 2020 Advisory on Ransomware, AECs reduce the transparency of CVC financial flows,
    including ransomware payments, through anonymizing features, such as mixing and cryptographic enhancements.
9. Data in Figures 1 and 2 differ slightly between filing date and transaction date, as the filing date can denote
    ransomware events that occurred outside the timeframe covered in this report. Filing date reflects financial
    institutions’ detection and compliance, whereas transaction date reflects the actual date of payments associated with
    incidents.
10. This includes ransomware-related transactions reported in SARs and does not include additional ransomware-related
    transactions identified by FinCEN’s blockchain analysis.

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                                            F I N A N C I A L                              T R E N D                 A N A L Y S I S

FinCEN and Treasury’s Office of Foreign Assets Control (OFAC) have released ransomware-
related advisories that, among other things, seek to promote reporting of ransomware-related
incidents.11 12 13 In the same month, the G7 released a ransomware annex to a statement on digital
assets that emphasized the importance of implementation of international anti-money laundering
and countering the financing of terrorism standards to counter ransomware-related money
laundering.14 Following the publication of these advisories, on 12 November 2020, FinCEN held
a virtual FinCEN Exchange focused on the growing concern with ransomware-related events and
efforts to combat the issue. This exchange included representatives from financial institutions,
technology firms, digital forensic incident response (DFIR) firms, virtual asset service providers
(VASPs), and federal government agencies.15 Following Treasury’s fall 2020 efforts to draw
attention to ransomware and potential associated reporting obligations, FinCEN observed a notable
increase in filings during the last quarter of 2020, which contributed to the overall rise in 2020
filings (see Figure 1). For example, during the first six months of 2021, of the 458 ransomware-
related transactions, 335 SARs referenced the key term “CYBER-FIN-2020-A006” from FinCEN’s
October 2020 ransomware advisory.FinCEN16  Financial Trend Analysis

        Figure 1. Number
                    Figure 1.of Ransomware-Related
                              Number of                    SARs
                                        Ransomware-Related SARs   and
                                                                and     Transactions,
                                                                    Transactions,           2011
                                                                                  2011 to June 202117to June 202117

                                           700                                                                                      635
                                                                                                                          602
                                           600
                                                                                                                            487
                                                                                                                                  458

                          Number of SARs
                                           500                                            431
                                           400                                              360
                                           300                                                                    243                     Transaction Date
                                                                                                 218 217 198        216
                                           200                                                              181                           Filing Date
                                                                                74
                                           100                 24 9   38             60
                                                 2 0    8 0                19
                                             0
                                                 2011   2012   2013   2014      2015      2016    2017   2018     2019    2020    2021
                                                                                          Year

                         Figure 2. Total Suspicious Amount from Ransomware-Related SARs and Transactions,
                                                         2011 to June 202118
11. See footnote seven.
                            700
12. “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments,”                    590 U.S. Department of the Treasury
    Advisory, 1 Oct. 2020,600https://home.treasury.gov/system/files/126/ofac_ransomware_advisory_10012020_1.pdf.
                                                                                             527
13. On 21 September 2021,500OFAC updated its ransomware-related advisory to encourage reporting and cyber resilience,
                                                                                               416 398

                          USD (Millions)
    “Updated Advisory on400Potential Sanctions Risks for Facilitating Ransomware                       Payments,” U.S. Department of the
    Treasury Advisory, 21 Sept. 2021, https://home.treasury.gov/system/files/126/ofac_ransomware_advisory.pdf.
                                                                                      281
                            300                                                                               Transaction Date
14. “Ransomware Annex to G7 Statement,” G7 Finance Ministers and 252                   Central Bank Governors, 13 Oct 2020,
                                                                    181                                       Filing Date
    https://home.treasury.gov/system/files/136/G7-Ransomware-Annex-10132020_Final.pdf.
                            200
                                                                      152 119
                                                                                102
15. “FinCEN Holds Virtual   100FinCEN Exchange on Ransomware,”   54         38
                                                                                  Financial Crimes Enforcement Network Press Release,
                                                                                   56
                                               35             20
    12 Nov. 2020, https://www.fincen.gov/news/news-releases/fincen-holds-virtual-fincen-exchange-ransomware.
                                  10  0 0.4 0
                                                   0.4
                                                       11 2.5
                              0
16. A number of the 335 SARs 2011  appeared
                                          2012   to reference
                                                2013 2014         FinCEN’s
                                                              2015 2016   2017 2020   Advisory
                                                                                 2018 2019   2020 on   Ransomware and noted “CYBER-FIN-
                                                                                                    2021
    2021-A006,” which FinCEN assesses to be a typographical         Year      error referring to “CYBER-FIN-2020-A006.”
17. 2021 figures report transaction dates during the review period. Transaction date data include SARs filed in July 2021
    with a transaction date before July 2021. FinCEN assessed SARs filed between 1 January 2020 and 31 July 2021 for
    accuracy, duplication, and false positives using both the narrative and the note to FinCEN field on SAR forms. Data
    from SARs filed between 1 January 2011 and 31 December 2019 reflect reports that contain “ransomware” in the
                     17 Figures for 2021 are from 1 January 2021 to 30 June 2021. Transaction date data include SARs filed in
    narrative.
                        July 2021 with a transaction date before July 2021. FinCEN assessed SARs filed between 1 January 2020
                        and 31 July 2021 for accuracy, duplication, and false positives using both the narrative and the note to
                        FinCEN field on SAR forms. Data from SARs filed between 1 January 2011 and 31 December 2019 reflect
                        reports that contain “ransomware” in the narrative. 4
                        18 Figures for 2021 are from 1 January 2021 to 30 June 2021. Transaction date data includes SARs filed in
                                                   100                       24 9     38           60
                                                          2 0         8 0                  19
                                                     0
                                                         2011     2012       2013     2014       2015     2016    2017     2018    2019    2020       2021
                                                                                                          Year
                                                    F I N A N C I A L                                      T R E N D                     A N A L Y S I S

       Figure 2. Total Suspicious
                    Figure 2.           Amount
                              Total Suspicious    from
                                               Amount     Ransomware-Related
                                                      from Ransomware-Related        SARs
                                                                              SARs and      and Transactions,
                                                                                       Transactions,
                                                 2011 to June 2021
                                                    2011 to June 202118 18

                                                   700
                                                                                                                                                        590
                                                   600
                                                                                                                                           527
                                                   500
                                                                                                                                             416 398

                                  USD (Millions)
                                                   400
                                                                                                                                   281                        Transaction Date
                                                   300
                                                                                                                                     252
                                                                                                          181                                                 Filing Date
                                                   200
                                                                                                            152 119
                                                                                                                           102
                                                   100                                         54                     38     56
                                                         10 0 0.4 0 35                112.5 20
                                                                                0.4
                                                     0
                                                         2011     2012       2013     2014       2015     2016    2017     2018    2019    2020       2021
                                                                                                          Year

Reported Ransomware-Related      FinCEN Financial             Transactions
                                                                   Trend Analysis            Substantially
Increased from        2020
              Figures for 2021 are from 1 January 2021 to 30 June 2021. Transaction date data include SARs filed in
                         17

            July 2021 with a transaction date before July 2021. FinCEN assessed SARs filed between 1 January 2020
               Reported Ransomware-Related Transactions Substantially Increased
               and 31 July 2021 for accuracy, duplication, and false positives using both the narrative and the note to
The number of from
             ransomware-related
               FinCEN2020
                        field                 SAR
                              on SAR forms. Data      filings
                                                  from SARs       fluctuated
                                                              filed between         in2011
                                                                             1 January  theandfirst   quarter
                                                                                                 31 December  2019of    2021 before
                                                                                                                   reflect
stabilizing in the The  number
                    second
                    reports that of
                      Figures for
                                      ransomware-related
                                 quarter       of1 2021.
                                 contain “ransomware”    in theSAR
                                                             Due     filings
                                                                      to
                                                                narrative.   fluctuated in
                                                                          lookback          the first
                                                                                          SARs        quarter of 2021
                                                                                                    reporting            before
                                                                                                                     ransomware     attacks over
                   stabilizing
                         18
                                in2021
                                   the are  from quarter
                                         second    Januaryof
                                                           2021  to 30Due
                                                              2021.    Juneto
                                                                            2021. Transaction
                                                                              lookback   SARsdate   data includes
                                                                                                reporting         SARs filed in
                                                                                                            ransomware
                   preceding
the course of the attacks
                    July 2021
                            over    a six
                              withthe       months,
                                      transaction
                                        course  ofdate    January
                                                       before July
                                                  the preceding    2021.  FinCENsaw
                                                                         2021
                                                                    six months,            sharp
                                                                                        a SARs
                                                                                  assessed
                                                                                  January  2021 filed increase
                                                                                                  saw between        in the
                                                                                                       a sharp 1increase
                                                                                                                  January  in number of SARs
                                                                                                                          2020
                    and 31 July 2021 for accuracy, duplication, and false positives. Data from SARs filed between 1 January
filed. SAR data the
                  reports
                       number  a of
                                  mean       average
                                     SARs filed.           of 76
                                                    SAR data        anda a
                                                                reports    meanmedian      average
                                                                                  average of 76   and a of
                    2011 and 31 December 2019 reflect reports that contain “ransomware” in the narrative.
                                                                                                              73.5average of
                                                                                                          median      ransomware-related
                   73.5 ransomware-related transactions per month between 1 January 2021 and 30 June 2021
transactions per month         during the review period (see Figure 3). The median 6
                    October 2021                                                                                         average payment
                   (see Figure 3). The median average payment amount for ransomware-related transactions
amount for   ransomware-related
                   between                     transactions
                              1 January 2021 and 30                 during
                                                         June 2021 was          the a slight
                                                                           $102,273,  review       period
                                                                                               increase        wasmedian
                                                                                                          from the     $102,273, a slight
increase from the median average payment amount of $100,000 for transactions
                   average   payment      amount   of $100,000   for transactions   between   1 January    2020 and   30 Junebetween 1 January
                   2020, according to SAR data (see Figure 4).19 SARs report that19between 1 January 2021 and
2020 and 30 June 302020,      according to SAR data (see Figure 4). SARs report that during the review
                      June 2021 the vast majority of ransomware-related payments were for less than $250,000
period the vast (see
                 majority
                        Figureof 5). ransomware-related payments were for less than $250,000 (see Figure 5).

                      Figure 3. of
          Figure 3. Number      Number of Ransomware-Related Transactions,
                                   Ransomware-Related         Transactions,JanuaryJanuary
                                                                                   2021 to June 2021 to June 202120
                                                                                              2021
                                                                                                                                                                            20

                                               200
                                                                172

                                               150

                              Number of SARs
                                                                                                109 103
                                                                                                                      90            90                92
                                               100                           84 84                               78
                                                                                                                              69                              Transaction Date
                                                          61                                                                                     57
                                                   50                                                                                                         Filing Date

                                                    0
                                                          January           February            March            April            May            June
                                                                                                          Month (2021)

18. 2021 figures report transaction dates during the review period. Transaction date data includes SARs filed in July 2021
    with a transaction date before July 2021. FinCEN assessed SARs filed between 1 January 2020 and 31 July 2021 for
    accuracy, duplication, and false positives. Data from SARs filed between 1 January 2011 and 31 December 2019 reflect
    reports that contain “ransomware” in the narrative.
19. Ransomware-related payment amounts vary greatly from as little as $1 to as much as $45 million in 2021. To reduce
    the effect of outliers only the median average is reported for this data set.
20. Eighty-three of the 172 SARs filed in January 2021 are lookback filings that report transactions that occurred before
    December 2020.
                        19Ransomware-related payment amounts vary greatly     5from as little as $1 to as much as $45 million in
                        2021. To reduce the effect of outliers only the median average is reported for this data set.
                                                   F I N AFinCEN
                                                           N C I AFinancial
                                                                   L T R E Trend
                                                                            N D Analysis
                                                                                 A N A L Y S I S

                 Figure  4. 4.4.
                           Total
                      Figure
                      Figure         Suspicious
                                 Total Suspicious
                                 Total Suspicious   Amount
                                                  Amount
                                                  Amount of
                                                         of     of  Ransomware-Related
                                                            Ransomware-Related
                                                            Ransomware-Related                  Transactions,
                                                                               Transactions, January
                                                                               Transactions, January 2021
                                                                                                     2021 to
                                                                                                          to
                                                             June 2021
                                                 January 2021 to June 2021
                                                             June 2021 21
                                                                      21        21

                                                  200
                                                  200
                                                                                181.5 181.4
                                                                                181.5 181.4

                                                  150
                                                  150

                             USD (Millions)
                                                                                                                               117.4
                                                                                                                               117.4
                                                                                                   94.1
                                                                                                   94.1          90.1
                                                                                                                 90.1
                                                  100
                                                  100
                                                                         64.8                                                          Transaction Date
                                                                                                                                       Transaction Date
                                                                    58.6 64.8
                                                                    58.6
                                                             44.2                               51.2
                                                                                                51.2
                                                  50
                                                  50    38.8 44.2
                                                        38.8                                                 38.8
                                                                                                             38.8                      Filing Date
                                                                                                                                       Filing Date
                                                                                                                          29.5
                                                                                                                          29.5

                                                   00
                                                        January
                                                        January     February
                                                                    February       March
                                                                                   March         April
                                                                                                 April        May
                                                                                                              May             June
                                                                                                                              June
                                                                                              Month (2021)
                                                                                              Month (2021)

              Figure 5. Figure
                       Ransomware-Related
                        Figure 5.
                               5.                   Payments
                                  Ransomware-Related Payments
                                  Ransomware-Related Payments by by
                                                              by     Value,
                                                                 Value,
                                                                 Value,       January
                                                                        January 2021
                                                                        January 2021       2021
                                                                                     to June
                                                                                     to June 2021 to June 2021
                                                                                             2021

                                                  70
                                                  70
                                                  60
                                                  60

                             Number of Payments
                                                  50
                                                  50
                                                  40
                                                  40
                                                  30
                                                  30
                                                  20
                                                  20
                                                  10
                                                  10
                                                  00
                                                         January
                                                         January        February
                                                                        February           March
                                                                                           March             April
                                                                                                             April               May
                                                                                                                                 May        June
                                                                                                                                            June
                                                                                       Transaction Date
                                                                                       Transaction Date (2021)
                                                                                                        (2021)
                                                                       0-250k
                                                                       0-250k       251k-500k
                                                                                    251k-500k      501k-1m
                                                                                                   501k-1m          1.1m-5m
                                                                                                                    1.1m-5m      5m+
                                                                                                                                 5m+
                                                                                   Value of
                                                                                   Value of Individual
                                                                                            Individual Payment
                                                                                                       Payment (USD)
                                                                                                               (USD)

68 Variants 68
            Identified,       Variant 1 Most Prevalent
               Variants Identified, Variant 1 Most Prevalent
                        Ransomware Variants:
                        Ransomware Variants: FinCEN
                                             FinCEN identified
                                                    identified 68
                                                               68 ransomware
                                                                  ransomware variants
                                                                             variants reported
                                                                                      reported in
                                                                                               in SAR
                                                                                                  SAR data
                                                                                                      data
Ransomware     Variants:    FinCEN
                  for transactions
                  for transactions         identified
                                     between 11
                                     between       January 68
                                                   January   2021 ransomware
                                                                   and 30
                                                             2021 and    30         2021. variants
                                                                              June 2021.
                                                                              June                       reported
                                                                                            Ransomware variant
                                                                                           Ransomware      variant     in SAR data for
                                                                                                                   analysis
                                                                                                                   analysis
                  can
                  can  help
                       help  determine
                            determine    potential
                                         potential    threat
                                                      threat  actors
                                                             actors   behind
                                                                     behind     an
                                                                                an  attack.
                                                                                    attack.
transactions during the review period. Ransomware variant analysis can help determine         Ninety
                                                                                              Ninety  SARs
                                                                                                      SARs   did
                                                                                                             did not
                                                                                                                 not name
                                                                                                                     name   the
                                                                                                                            the     potential
                  ransomware variant
                  ransomware      variant used
                                           used inin the
                                                     the attack,
                                                         attack, and
                                                                  and some
                                                                        some SARs
                                                                                SARs reported
                                                                                        reported multiple
                                                                                                   multiple incidents
                                                                                                             incidents
threat actors behind   an attack.
                  involving
                  involving   more   thanNinety
                              more than    one         SARs
                                                 variant.
                                           one variant.    Figures           andname
                                                                 did6,6, 7,not
                                                           Figures       7, and     depictthe
                                                                                 88 depict        ransomware
                                                                                             the suspicious
                                                                                            the  suspicious  amounts,
                                                                                                             amounts, variant used in the
attack, and some SARs reported multiple incidents involving more than one variant. Figures 6, 7,
and 8 depict the suspicious amounts, number, and value of transactions for the 10 variants with the
                  amounts
highest payment The The sharp
                         sharp increase
                        21
                        21     increase highest
                                  andinin total        number
                                          total suspicious
                                                suspicious  amount for
                                                            amount          incidents
                                                                      ofMarch
                                                                     for   March             intwo
                                                                                  2021 reflects
                                                                                 2021  reflects  SARs.
                                                                                                two       22 SARs,
                                                                                                    high-value
                                                                                                    high-value SARs, and
                                                                                                                     and aa
                        single lookback
                        single lookback SAR
                                        SAR reporting
                                             reporting multiple
                                                        multiple ransom
                                                                 ransom payments
                                                                        payments over
                                                                                 over the
                                                                                      the course
                                                                                          course of
                                                                                                 of aa year
                                                                                                       year that
                                                                                                            that account
                                                                                                                 account for
                                                                                                                         for
                        approximately 25
                        approximately  25 percent
                                          percent of
                                                  of the
                                                     the March
                                                         March total.
                                                                total.
The top 10 variants with the highest cumulative payment amounts identified in SARs during the
review period accounted     for $217.56 million in suspicious activity (see Figure 88
                  October 2021
                  October 2021                                                     6). The highest
total suspicious payment amounts for individual variants reported in SARs range from $30 to $76
million. Monthly suspicious payment amounts reported in SARs for the top 10 variants range from
$3,095 to $43.06 million with a median average of $27 million and mean average of $36.26 million.
In June 2021, the highest cumulative suspicious payment amounts were associated with Variant 1
($11.78 million) and Variant 2 ($8.53 million), according to SAR data.

21. The sharp increase in total suspicious amount for March 2021 reflects two high-value SARs, and a single lookback
    SAR reporting multiple ransom payments over the course of a year that account for approximately 25 percent of the
    March total.
22. Actual variant names are redacted for operational security purposes.

                                                                                                  6
                      activity (see Figure 6). The highest total suspicious payment amounts for individual
                      variants reported in SARs range from $30 to $76 million. Monthly suspicious payment
                      amounts reported in SARs for the top 10 variants range from $3,095 to $43.06 million with a
                      median average of $27 million and mean average of $36.26 million. In June 2021, the
                      highestF I N     A N
                               cumulative       C I A L
                                           suspicious paymentT R      E N
                                                                 amounts     Dassociated
                                                                          were    A N with
                                                                                         A LVariant
                                                                                                Y S1 I S
                                                                                                       ($11.78
                      million) and Variant 2 ($8.53 million), according to SAR data.

   Figure 6. Top Figure
                Ransomware       Variants by
                        6. Top Ransomware      Suspicious
                                          Variants by           Payment
                                                      Suspicious Payment    Amount
                                                                          Amount with with  Transaction Dates
                                                                                     Transaction
                                 Between January 2021 and June 2021
                                     Dates Between  January 2021 and June 2021

                                               100

                                                80

                              USD (Millions)
                                                60

                                                40

                                                20

                                                   0
                                                        Jan           Feb                Mar             Apr             May     Jun
                                                                                           Month (2021)

                                                              Variant 1     Variant 2     Variant 3    Variant 7    Variant 9

                                                              Variant 11    Variant 12    Variant 13   Variant 14   Variant 15

                      FinCEN identified 242 SARs filed on the top 10 most frequently reported variants with
FinCEN identifiedtransaction
                    242 SARs      filed
                              dates     on1the
                                    between        top2021
                                              January   10 and
                                                            most    frequently
                                                                30 June             reported
                                                                        2021 (see Figure         variants
                                                                                         7). These SARs mostwith transaction
dates during the review     periodVariant
                  frequently report   (see 1 (64
                                            Figure    7). followed
                                                 reports), Theseby   SARs    most
                                                                      Variant 2      frequently
                                                                                (42 reports)         report
                                                                                             and Variant 3 (32 Variant 1 (64
                  reports). The number of monthly SARs for the top 10 variants range from 0 to 22 reports.
reports), followed by Variant 2 (42 reports) and Variant 3 (32 reports). The number of monthly
                  In June 2021, SARs most frequently reported Variant 2 (18 reports) and Variant 1 (six
SARs for the top 10   variants range from 0 to 22 reports. In June 2021, SARs most frequently
                  reports).
reported Variant 2 (18 reports) and  FinCEN       Financial
                                          Variant 1               Trend Analysis
                                                         (six reports).

          Figure 7. Top  Ransomware
                      Figure              Variants
                             7. Top Ransomware        by
                                               Variants by Number     of SARs
                                                           Number of SARs        with Transaction
                                                                           with Transaction Dates Dates
                                    Between    January
                                          Between          2021and
                                                  January 2021   and
                                                                   JuneJune
                                                                        2021 2021

                                            60

                                            50
                      22   Actual variant names are redacted for operational security purposes.

                           Number of SARs
                          40 2021
                      October                                                                                                          9
                                            30

                                            20

                                            10

                                               0
                                                       Jan          Feb                 Mar             Apr              May     Jun
                                                                                          Month (2021)

                                                              Variant 1     Variant 2    Variant 3     Variant 4    Variant 5

                                                              Variant 6     Variant 7    Variant 8     Variant 9    Variant 10

                 FinCEN analysis of reported ransomware-related transactions between 1 January 2021 and
FinCEN analysis of   reported
                 30 June          ransomware-related
                         2021 determined   that Variant 1 had thetransactions
                                                                  highest number of during
                                                                                       incidentsthe
                                                                                                 (64),review
                                                                                                       Variant 3 period
                 had the highest total dollar value of transactions ($75.8 million), and Variant 2 had the
determined that Variant    1 had the highest number of incidents (64), Variant 3 had the highest total
                 highest median average incident value ($353,800) for known variants (see Figure 8).23
dollar value of transactions ($75.8 million), and Variant 2 had the highest median average incident
value ($353,800) for known variants (see Figure 8).23

23. The data in this report consists only of information received through BSA reporting and is not a complete
    representation of all ransomware attacks or payments during the review period.

                                                                                              7
                           F I N A N C I A L            T R E N D       A N A L Y S I S

  Figure 8. Ransomware Variants by Number and Value of Transactions with Transaction Dates
                            Between January 2021 and June 202124

                                     Number of            Total Dollar Value              Median Average
  Ransomware Variant
                                     Incidents               of Incidents                 Incident Value25

  Variant 1                     64                       ~$30.7 million                ~$177,800

  Variant 2                     42                       ~$25.3 million                ~$353,800

  Variant 3                     32                       ~$75.8 million                ~$200,000

  Variant 4                     25                       ~$2.8 million                 ~$73,900

  Variant 5                     15                       ~$800,000                     ~$70,000

  Variant 6                     13                       ~$1.4 million                 ~$75,600

  Variant 7                     14                       ~$7 million                   ~$300,000

  Variant 8                     15                       ~$3.7 million                 ~$176,000

  Variant 9                     10                       ~$3.7 million                 ~$140,000

  Variant 10                    12                       ~$1.3 million                 ~$125,000

  Total                         242                      ~$152.5 million               ~$148,400

Digital Forensic Incident Response Firms File Majority of
Ransomware-Related SARs
During the review period, U.S.-based DFIR firms submitted the majority of ransomware-related
SARs, or approximately 63 percent of ransomware-related SARs (see Figure 9).26 In addition,
depository institutions and CVC exchanges submitted over a third of SARs at 17 percent and 19
percent of SARs, respectively. Other institutions including broker-dealers, an insurance company,
and casinos submitted less than 10 percent of the total SARs.

24. SARs report 90 transactions with a total value of $143.8 million and a median average incident value of $102,273
    related to unknown variants.
25. To reduce the effect of outliers only the median average is reported for this data set.
26. As noted in FinCEN’s 2020 Advisory on Ransomware, DFIR companies help victims respond to cyber-attacks
    and may facilitate ransomware payments to cybercriminals by converting customer fiat funds to CVC and then
    transferring the funds to criminal controlled accounts.

                                                            8
                                                                            FinCEN Financial
                                                            F I N A N C I A L
                                                                                             Trend Analysis
                                                                                       T R E N D A N A L Y S I S
                             Figure 9. Ransomware-Related Transactions by Institution Type, January 2021 to June
   Figure 9. Ransomware-Related Transactions by  Institution Type, January 2021 to June 202127
                                             202127

                                                            80%

                             Percent of Filings per Month
                                                            70%
                                                            60%
                                                            50%                                                        CVC Exchanges
                                                            40%
                                                                                                                       DFIR
                                                            30%
                                                            20%                                                        Other
                                                            10%                                                        Dep. Inst.
                                                            0%
                                                                  January    February   March     April   May   June
                                                                                         Month (2021)

A small number ofADFIR    firmsofsubmitted
                   small number                 ransomware-related
                                  DFIR firms submitted                      SARs
                                                        ransomware-related SARs   forfor  transactions conducted
                                                                                      transactions
                 conducted between 1 January 2021 and 30 June 2021. These DFIR firms filed 290
during the reviewransomware-related
                  period. TheseSARs. DFIR28 firms filed 290 ransomware-related SARs.
                                                                                                   28

Majority of Reported       Ransomware-Related Payments in Bitcoin
             Majority of Reported Ransomware-Related Payments in Bitcoin
                        FinCEN identified BTC as the most common ransomware-related payment method in
FinCEN identified BTC
                   reportedas the    mostFinCEN
                            transactions.    common        ransomware-related
                                                    also observed that                  payment
                                                                       incidents requesting         method
                                                                                            Monero (XMR), an in reported
                   AEC, is on track to increase slightly compared to 2020.
transactions. FinCEN also observed that incidents requesting Monero (XMR), an AEC, is on track
to increase slightly compared       to 2020.
                   Ransomware-Related     Payment Methods: Of the SARs reporting ransomware-related
                        payments between 1 January 2021 and 30 June 2021 that identified a specific CVC, the vast
Ransomware-Related       Payment
                  majority reported   Methods:
                                    payments  made inOf   the
                                                       BTC.      SARs reporting ransomware-related payments
                                                             29 Sixty-four SARs that report a ransomware-

                  related payment did not identify a specific CVC. While there are thousands of CVCs in the
during the reviewmarket,
                   period      that identified a specific CVC, the vast majority reported payments
                           the SAR data only noted attackers requested BTC and XMR as methods for
made in BTC. Sixty-four
              29
                                SARspayment
                  ransomware-related    that report     a ransomware-related
                                                during the  observed timeframe.          payment did not identify
a specific CVC. While there are thousands of CVCs in the market, the SAR data only noted
attackers requested BTC and XMR as methods for ransomware-related payment during the
observed timeframe.

Monero Ransomware-Related               Requests:
                   The “CVC” category includes
                        27                                FinCEN
                                                   CVC kiosks.            identified
                                                                The “Other”                17 casinos, securities
                                                                              category includes ransomware-related    broker- SARs during
                 dealers, wealth management firms, and insurance companies.
the review period requesting         payment in XMR (see Figure 10). In some instances, the attacker
                   FinCEN identified a small number of DFIR firms that purport to negotiate on behalf of victims in SAR
                        28

provided both an XMR and a not
                 data. FinCEN   does  BTC haveaddress,
                                               information onand     imposed
                                                               the total              an firms
                                                                         number of DFIR   extra that fee
                                                                                                     exist. if payment was made in
                   As noted in FinCEN’s 2020 Advisory on Ransomware, cybercriminals usually require ransomware
                        29

BTC. In other instances,      they
                 payments to be       exclusively
                                 denominated              requested
                                                in CVCs, most                payment
                                                               commonly in BTC.     However,inthey are
                                                                                                 XMR,   also but     accepted payment in
                                                                                                               increasingly
BTC after negotiation.
                 requiring or incentivizing victims to pay in AECs  that  reduce the transparency  of CVC    financial flows,
                        including ransomware payments, through anonymizing features, such as mixing and cryptographic
                        enhancements.
                        October 2021                                                                                                12

27. The “CVC” category includes CVC kiosks. The “Other” category includes casinos, securities broker-dealers, wealth
    management firms, and insurance companies.
28. FinCEN identified a small number of DFIR firms that purport to negotiate on behalf of victims in SAR data. FinCEN
    does not have information on the total number of DFIR firms that exist.
29. As noted in FinCEN’s 2020 Advisory on Ransomware, cybercriminals usually require ransomware payments to
    be denominated in CVCs, most commonly in BTC. However, they are also increasingly requiring or incentivizing
    victims to pay in AECs that reduce the transparency of CVC financial flows, including ransomware payments,
    through anonymizing features, such as mixing and cryptographic enhancements.

                                                                                                    9
                          F I N A N C I A L          T R E N D        A N A L Y S I S

                       Figure 10. Monero (XMR) Ransomware-Related Requests,
                                      January 2021 to June 2021

                                                             Number of            Value of Total Payments
             Circumstance of Request
                                                             Payments                      (USD)

  Attacker provided both XMR and BTC                              7            ~$34 million
  wallet addresses

  Attacker requested only XMR                                     7            ~$2.4 million

  Other30                                                         3            ~$500,000

  Total                                                          17            ~$37 million

Communication via The Onion Router and Email Systems
Victims typically communicated with the threat actors via The Onion Router (Tor), encrypted
email, non-encrypted email, and unidentified web portals provided by the attackers, according
to SAR data. Tor employs encryption to allow for anonymous browsing as traffic moves within a
network. The victims, or DFIR firms representing them, primarily engaged with the threat actors
using a Tor website provided by the attackers to negotiate the ransomware-related payment,
according to SAR data (see Figure 11). After negotiating the ransom amount, the DFIR firm or
victim would make payment in exchange for decryption keys. Some variants required further
negotiation and escalating payment demands even after initial payments were made.

               Figure 11. Ransomware-Related Payments by Communication Method,
                                   January 2021 to June 2021

    Communication Method                     Number of Transactions                   Transaction Value

  Tor                                   192                                    ~$165.6 million

  Email                                 111                                    ~$41.5 million

  Other31                               10                                     ~$2.5 million

  Unknown                               145                                    ~188.4 million

  Total                                 458                                    ~$398 million

30. FinCEN identified three ransomware-related SARs mentioning Monero as a potential payment method, but did not
    explicitly state whether Monero was the exclusive payment method requested.
31. “Other” includes communication methods such as web portals and communication platforms not explicitly stated in
    SARs.

                                                        10
                               F I N A N C I A L                 T R E N D          A N A L Y S I S

177 Unique Wallet Addresses Identified for Top 10 Ransomware
Variants
FinCEN identified 177 unique wallet addresses used for ransomware-related payments by the top
10 most common ransomware variants reported in SARs during the review period (see Appendix
1 for detailed information on each variant).32 FinCEN conducted analysis using commercially
available analytics tools to determine the source of funds victims used to pay ransoms and the
overall BTC sent from these threat actor wallet addresses to known entities. Not all of the funds
sent from these wallet addresses are definitively related to ransomware payments; however, all
of the exchanges and services identified below were at a minimum a direct counterparty to wallet
addresses that received ransomware-related payments (see Figure 13).

Wallets associated with the 10 variants examined sent BTC valued at $5.2 billion to known entities,
directly or indirectly, including 51 percent to exchanges, 43 percent to other CVC services, five
percent to darknet marketplaces, and one percent to mixing services.33 34 35 These percentages
identify transactions traced to known entities and may not represent the final cash out locations
after obfuscation of funds. While the total in Figure 13 indicates the 10 variants sent one percent of
all funds to mixing services, this percentage varies when broken down by variant (see Appendix 1).
The totals in Figure 13 include 177 wallet addresses identified in SARs and approximately 423,000
wallet addresses assessed to be associated with the relevant ransomware variants by commercially
available analytics tools.36    FinCEN Financial Trend Analysis
                 Figure 13. Top 10 Ransomware Variant Transactions with Known Entities

                      Ransomware-Related
32. Most of the 458 SARs FinCEN                     Money
                                         examined did          Laundering
                                                          not report          Typologies
                                                                      the attacker’s   wallet address.
33. Victims predominantly      sourced funds from U.S.-registered exchanges.
                      FinCEN identified at least six money laundering typologies attributed to ransomware
34. “Other” includesvariants
                       unidentified
                               in 2021 CVC      services,
                                         by analyzing     as well as unspent
                                                       ransomware-related       and
                                                                            SARs,     untracedblockchain
                                                                                   conducting    CVC. analysis,
35. Direct transactions
                      andare  funds sent
                          leveraging         from one
                                        industry         party to
                                                  observations  andanother  without
                                                                    outreach. For      intermediaries.
                                                                                  example,                Indirect
                                                                                            participants in this     transactions are funds
                                                                                                                 year’s
    sent from one party   to one or
                      FinCEN   Exchangemore    intermediary
                                            on ransomware      wallet address
                                                            separately           before
                                                                        substantiated    the first
                                                                                      these        encountered
                                                                                            observations           service.
                                                                                                          citing their
36. FinCEN identified own  analysis
                         177  walletofaddresses
                                         ransomware   activity.37 with the 10 ransomware variants in SAR data and a total of
                                                    associated
    422,895 wallet addresses associated with the ransomware variants using commercially available analytics tools.
    This difference isThreat    Actors
                       likely due         Increasingly Request
                                     to underreporting               Payments
                                                            of ransomware          in AECsNot all of the funds sent from these wallet
                                                                              incidents.
    addresses are definitively    relatedoftoransomware-related
                      FinCEN’s analysis         ransomware payments;        however,
                                                                    SARs found          all of the exchanges
                                                                                 ransomware-related   paymentsand are services identified in
    Figure 13 were atoften
                       a minimum        a direct  counterparty    to wallet  addresses   that  received   ransomware-related
                            initially requested in BTC, though threat actors may request payments in AECs, most                  payments.
                        commonly, XMR. FinCEN observed a 10 to 20 percent surcharge or discount for victims
                        paying in BTC, and, on some occasions, threat actors exclusively requested payment in
                        XMR.                                        11
                           F I N A N C I A L           T R E N D        A N A L Y S I S

Ransomware-Related Money Laundering Typologies
FinCEN identified at least six money laundering typologies attributed to ransomware variants in 2021
by analyzing ransomware-related SARs, conducting blockchain analysis, and leveraging industry
observations and outreach. For example, participants in this year’s FinCEN Exchange on ransomware
separately substantiated these observations citing their own analysis of ransomware activity.37

Threat Actors Increasingly Request Payments in AECs
FinCEN’s analysis of ransomware-related SARs found ransomware-related payments are often
initially requested in BTC, though threat actors may request payments in AECs, most commonly
XMR. FinCEN observed a 10 to 20 percent surcharge or discount for victims paying in BTC, and,
on some occasions, threat actors exclusively requested payment in XMR.

Threat Actors Avoided Reusing Wallet Addresses
After receiving illicit funds from a victim, ransomware actors layered funds through multiple
wallet addresses and avoided reusing wallet addresses for each attack, according to SAR data.
Threat actors laundered the payments from each ransomware event separately, to minimize
consolidation into single wallet addresses.

Centralized CVC Exchanges are Preferred Cash-out Points
Threat actors identified from SARs primarily use foreign centralized exchanges for ransomware-
related deposits, including exchanges incorporated in high-risk jurisdictions that may have
opaque ownership structures or that may have inadequate AML/CFT compliance standards.
This observation is also corroborated by commercial blockchain analytic companies that note the
use of exchanges incorporated in jurisdictions that may not enforce know your customer (KYC)
requirements or require the reporting of suspicious transactions.38 Non-compliant centralized
exchanges are possibly a key step in the layering and obfuscation process of laundering funds from
CVC to fiat currency.

“Chain Hopping” is Used to Obfuscate Financial Trails on Blockchains
Illicit actors often engage in the practice of “chain hopping” to obfuscate the origin of their funds.
Chain hopping refers to the practice of converting one CVC into a different CVC at least once
before moving the funds to another service or platform. This practice allows threat actors to
convert illicit BTC proceeds into an AEC like XMR at CVC exchanges or services. Threat actors can
then transfer the converted funds to large CVC services and MSBs with lax compliance programs.

37. FinCEN held the second Ransomware FinCEN Exchange on 10 Aug. 2021. See
    https://www.fincen.gov/news/news-releases/fincen-holds-second-virtual-fincen-exchange-ransomware.
38. Dr. Tom Robinson, “DarkSide Ransomware has Netted Over $90 million in Bitcoin,” Elliptic Blog, 18 May 2021,
    https://www.elliptic.co/blog/darkside-ransomware-has-netted-over-90-million-in-bitcoin, accessed 3 Sept. 2021.

                                                          12
                           F I N A N C I A L           T R E N D        A N A L Y S I S

Mixing Services are Prevalent in 2021
FinCEN observed an increased use of mixing services in SARs.39 Mixers are websites or software
designed to conceal or obfuscate the source or owner of CVC. Mixers may have obligations as
money transmitters under the BSA. For example, in October 2020 FinCEN assessed a $60 million
civil money penalty against Larry Dean Harmon for operating the mixing service Helix and failing
to register with FinCEN, maintain an effective AML program, and file SARs on suspicious activity
that went through the Mixer.40 Mixing is done either as a general privacy measure or for covering
up the movement of funds obtained from theft, darknet markets, or other illicit sources.

• According to a May 2020 report by Crystal Blockchain, there was a rapid growth in the amount
  of BTC sent from darknet entities to mixers in Q1 2020.41

• According to Chainalysis’ mid-year report on ransomware, mixing services are still a preferred
  destination for illicit funds behind centralized exchanges.42

• FinCEN’s analysis of the 10 most common ransomware variants in SAR data during the review
  period indicate use of mixers varies by variant. (See Appendix 1).

Decentralized Exchanges Likely Used to Convert Illicit Proceeds
Ransomware-related payments are being converted to other types of CVCs through decentralized
exchanges or other DeFi applications. Some DeFi applications allow for automated peer-to-
peer transactions without the need for an account or custodial relationship. FinCEN analysis
of transactions on the BTC blockchain identified ransomware-related funds sent indirectly to
addresses associated with open protocols for use on DeFi applications.

Ransomware Detection, Mitigation, and Reporting
Financial institutions play an important role in protecting the U.S. financial system from ransomware-
related threats through compliance with BSA obligations. Financial institutions should determine if a
SAR filing is required or appropriate when dealing with a ransomware incident, including ransomware-
related payments made by financial institutions that are victims of ransomware.43 Financial institutions
may also file with FinCEN a report of any suspicious transaction it believes relates to the possible
violation of any law or regulation but whose reporting is not required by 31 CFR Chapter X.

39. For more information on mixers, see FinCEN Guidance FIN-2019-G001, 9 May 2019, p.19-20 https://www.fincen.gov/
    sites/default/files/2019-05/FinCEN Guidance CVC FINAL 508.pdf.
40. “In the matter of Larry Dean Harmon d/b/a Helix, Assessment of Civil Money Penalty Number 2020-02,” FinCEN, 19
    Oct. 2020, https://www.fincen.gov/sites/default/files/enforcement_action/2020-10-19/HarmonHelix Assessment and
    SoF_508_101920.pdf.
41. Crystal analytics team, “Darknet Use and Bitcoin — A Crypto Activity Report by Crystal Blockchain,” Crystal
    Blockchain, 19 May 2020, https://crystalblockchain.com/articles/darknet-use-and-bitcoin-a-crypto-activity-report-by-
    crystal-blockchain/, accessed 26 Aug. 2021.
42. Chainalysis, “Ransomware 2021: Critical Mid-Year Update,” July 2021, https://blog.chainalysis.com/reports/
    ransomware-update-may-2021, accessed 26 Aug. 2021.
43. For more information see FinCEN Advisory #FIN-2020-A006, 1 Oct. 2020, https://www.fincen.gov/sites/default/files/
    advisory/2020-10-01/Advisory Ransomware FINAL 508.pdf.

                                                          13
                          F I N A N C I A L           T R E N D       A N A L Y S I S

Detection and Mitigation Recommendations
Ransomware is a serious cybersecurity concern for which FinCEN recommends the following
actions:

1. Incorporate IOCs from threat data sources into intrusion detection systems and security alert
    systems to enable active blocking or reporting of suspected malicious activity.

2. Contact law enforcement immediately regarding any identified activity related to ransomware,
   and contact OFAC if there is any reason to suspect the cyber actor demanding ransomware
   payment may be sanctioned or otherwise have a sanctions nexus.44 Please see contact
   information for the Federal Bureau of Investigation (FBI), Cybersecurity and Infrastructure
   Security Agency (CISA), OFAC, and U.S. Secret Service at the end of this report.

3. Report suspicious activity to FinCEN, highlighting the presence of “Cyber Event Indicators.”
   IOCs, such as suspicious email addresses, file names, hashes, domains, and IP addresses, can
   be provided in the SAR form. Information regarding ransomware variants, AECs requested for
   payment, or other information may also be useful to law enforcement and for trend analysis
   in addition to virtual currency addresses and transaction hashes associated with ransomware
   payments.

4. Review financial red flag indicators of ransomware in the “Advisory on Ransomware and the
   Use of the Financial System to Facilitate Ransom Payments” issued by FinCEN in October
   2020.45

Further, ransomware is a complex cybersecurity problem requiring a variety of preventive,
protective, and preparatory best practices. CISA’s StopRansomware.gov offers a one-stop-shop for
government resources containing alerts, guides, fact sheets, and training all focused on reducing
the risk of ransomware. CISA and the Multi-State Information Sharing and Analysis Center’s (MS-
ISAC’s) Ransomware Guide provides high-level prevention best practices and a response checklist
while the National Institute of Standards and Technology’s (NIST’s) Data Integrity: Detecting and
Responding to Ransomware and Other Destructive Events offers a comprehensive focus on detailed
methods and potential tool sets that can detect, mitigate, and contain data integrity events in the
components of an enterprise network.

44. For more information see “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments,”
    U.S. Department of the Treasury Advisory, 21 Sept. 2021, https://home.treasury.gov/system/files/126/ofac_
    ransomware_advisory.pdf.
45. For more information see FinCEN Advisory #FIN-2020-A006, 1 Oct. 2020, https://www.fincen.gov/sites/default/files/
    advisory/2020-10-01/Advisory Ransomware FINAL 508.pdf.

                                                         14
                      F I N A N C I A L       T R E N D    A N A L Y S I S

Reporting Suspicious Cyber Activity
To report an intrusion and request technical assistance, contact CISA at cisaservicedesk@cisa.
dhs.gov or 888-282-0870, or FBI through a local field office or FBI’s Cyber Division at CyWatch@
fbi.gov or 855-292-3937, or any U.S. Secret Service local field offices to report a crime. Contact
OFAC at [email protected] if there is any reason to suspect the cyber actor demanding
ransomware payment may be sanctioned or otherwise have a sanctions nexus. For formal guidance
to financial institutions on reporting ransomware-related incidents, please refer to FinCEN’s
resource page on advisories, at https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets.

The information in this report is based on ransomware-related information obtained from analysis
of BSA data, trade publications, and commercial reporting, as well as insights from law enforcement
and other partners. FinCEN welcomes feedback on this report, particularly from financial
institutions. Please submit feedback to the FinCEN Regulatory Support Section at [email protected].

                                                 15
                          F I N A N C I A L          T R E N D       A N A L Y S I S

                     Appendix 1: Ransomware Variant Analysis
FinCEN determined the top 10 most common ransomware variants reported in SAR data and
reviewed open-source reporting to determine dates of activity and accepted payment method(s).
FinCEN identified unique wallet addresses used for ransomware-related payments by the top 10
most common variants and conducted analysis using commercially available technology. These
identified wallet addresses sent BTC to different CVC services including exchanges, darknet markets
(DNM), mixers, licit and illicit CVC service categories including untraced and unspent BTC.

                                   Accept Accept              Sent BTC (USD)
Ransomware          Start/End
                                   XMR     BTC Exchange    DNM       Mixer Other 46 Total
  Variant             Date
                                   (Y/N)  (Y/N)
                  April 2019 -                   ~$6.3              ~$6.5   ~$32.3  ~$46
Variant 1                            Y      Y            ~$826,000
                  July 2021                      million            million million million
                  December
                                                         ~$66.1       ~$7.3           ~$4       ~$161     ~$238.5
Variant 2         2019 -              N          Y
                                                         million      million         million   million   million
                  present
                  August 2020                            ~$14.3                 ~$6.5           ~$76.8    ~$98.2
Variant 3                              Y         Y                    ~$609,000
                  - May 2021                             million                million         million   million
                  June 2020 -                            ~$4.9                  ~$1.6           ~$6.3     ~$13.5
Variant 4                             N          Y                    ~$660,000
                  June 2021                              million                million         million   million
                  September
                                                         ~$1.7        ~$241.6         ~$9.7     ~$1.7     $3.6
Variant 5         2019 -              N          Y
                                                         billion      million         million   billion   billion
                  present
                  July 2018 -                            ~$604.4                      ~$2.2     ~$184.5   ~$791.7
Variant 6                             N          Y                    ~$622,700
                  present                                million                      million   million   million
                  October 2019                           ~$3                          ~$2.3     ~$3.5     ~$8.8
Variant 7                             N          Y                    ~$3,600
                  - present                              million                      million   million   million
                  December
                                                         ~$240                        ~$1       ~$64.3    ~$305.8
Variant 8         2019 -              N          Y                    ~$740,000
                                                         million                      million   million   million
                  present
                  November
                                                                                                ~$6.9     ~$7.5
Variant 9         2019 -              N          Y       ~$519,000 ~$79,000           ~$9,900
                                                                                                million   million
                  present
                  September
                                                         ~$8.4                        ~$1.3     ~$11      ~$20.7
Variant 10        2019 -              N          Y                    ~$76,300
                                                         million                      million   million   million
                  present
                                                         ~$2.6        ~$252.5         ~$35.2    ~$2.3     ~$5.2
Total
                                                         billion      million         million   billion   billion

46. “Other” includes unidentified CVC services as well as unspent and untraced CVC.

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