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9/21/2021

Treasury Takes Robust Actions to Counter Ransomware | U.S. Department of the Treasury

Treasury Takes Robust Actions to Counter Ransomware
September 21, 2021

Targets First Virtual Currency Exchange for Laundering Cyber Ransoms
OFAC Updates Ransomware Advisory to Encourage Reporting and Cyber Resilience
WASHINGTON — As part of the whole-of-government e ort to counter ransomware, the U.S.
Department of the Treasury today announced a set of actions focused on disrupting criminal
networks and virtual currency exchanges responsible for laundering ransoms, encouraging
improved cyber security across the private sector, and increasing incident and ransomware
payment reporting to U.S. government agencies, including both Treasury and law
enforcement. Treasury’s actions today advance the United States government’s broader
counter-ransomware strategy, which emphasizes the need for a collaborative approach to
counter ransomware attacks, including partnership between the public and private sector
and close relationships with international partners.
“Ransomware and cyber-attacks are victimizing businesses large and small across America
and are a direct threat to our economy. We will continue to crack down on malicious actors,”
said Treasury Secretary Janet L. Yellen. “As cyber criminals use increasingly sophisticated
methods and technology, we are committed to using the full range of measures, to include
sanctions and regulatory tools, to disrupt, deter, and prevent ransomware attacks.”
Ransomware attacks are increasing in scale, sophistication, and frequency, victimizing
governments, individuals, and private companies around the world. In 2020, ransomware
payments reached over $400 million, more than four times their level in 2019. The U.S.
government estimates that these payments represent just a fraction of the economic harm
caused by cyber-attacks, but they underscore the objectives of those who seek to weaponize
technology for personal gain: to disrupt our economy and damage the companies, families,
and individuals who depend on it for their livelihoods, savings, and futures. In addition to the
millions of dollars paid in ransoms and recovery, the disruption to critical sectors, including
financial services, healthcare, and energy, as well as the exposure of confidential
information, can cause severe damage.
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Some virtual currency exchanges are a critical element of this ecosystem, as virtual currency
is the principal means of facilitating ransomware payments and associated money
laundering activities. The United States has been a leader in applying its anti-money
laundering/countering the financing of terrorism (AML/CFT) framework in the virtual currency
area, including with the Financial Crimes Enforcement Network (FinCEN) publishing guidance
regarding the application of Bank Secrecy Act rules in this area in 2013 and 2019. FinCEN has
also taken important enforcement action against non-compliant virtual currency money
transmitters facilitating ransomware payments, such as BTC-e in 2017 and the virtual
currency mixing service Helix in 2020. In addition, the United States is taking steps to
improve transparency regarding ransomware attacks and associated payments.

DESIGNATION OF F IRST VIRTUAL CURRENCY EXCHANGE
F OR COMPLICIT F INANCIAL SERVICES
Today’s actions include the Department of the Treasury’s O ice of Foreign Assets Control’s
(OFAC) designation of SUEX OTC, S.R.O. (SUEX), a virtual currency exchange, for its part in
facilitating financial transactions for ransomware actors. SUEX has facilitated transactions
involving illicit proceeds from at least eight ransomware variants. Analysis of known SUEX
transactions shows that over 40% of SUEX’s known transaction history is associated with
illicit actors. SUEX is being designated pursuant to Executive Order 13694, as amended, for
providing material support to the threat posed by criminal ransomware actors.
Virtual currency exchanges such as SUEX are critical to the profitability of ransomware
attacks, which help fund additional cybercriminal activity. Treasury will continue to disrupt
and hold accountable these entities to reduce the incentive for cybercriminals to continue to
conduct these attacks. This action is the first sanctions designation against a virtual currency
exchange and was executed with assistance from the Federal Bureau of Investigation.
While most virtual currency activity is licit, virtual currencies can be used for illicit activity
through peer-to-peer exchangers, mixers, and exchanges. This includes the facilitation of
sanctions evasion, ransomware schemes, and other cybercrimes. Some virtual currency
exchanges are exploited by malicious actors, but others, as is the case with SUEX, facilitate
illicit activities for their own illicit gains. Treasury will continue to use its authorities against
malicious cyber actors in concert with other U.S. departments and agencies, as well as our
foreign partners, to disrupt financial nodes tied to ransomware payments and cyber-attacks.
Those in the virtual currency industry play a critical role in implementing appropriate
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AML/CFT and sanctions controls to prevent sanctioned persons and other illicit actors from
exploiting virtual currencies to undermine U.S foreign policy and national security interests.

SANCTIONS IMPLICATIONS
As a result of today’s designation, all property and interests in property of the designated
target that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally
prohibited from engaging in transactions with them. Additionally, any entities 50% or more
owned by one or more designated persons are also blocked. In addition, financial
institutions and other persons that engage in certain transactions or activities with the
sanctioned entities and individuals may expose themselves to sanctions or be subject to an
enforcement action. Today’s action against SUEX does not implicate a sanctions nexus to any
particular Ransomware-as-a-Service (RaaS) or variant.

OFAC UPDATES ADVISORY ON POTENTIAL SANCTIONS
RISKS F OR FACILITATING RANSOMW ARE PAY MENTS
OFAC today also released an Updated Advisory on Potential Sanctions Risks for Facilitating
Ransomware Payments

. The Advisory emphasizes that the U.S. government continues to

strongly discourage the payment of cyber ransom or extortion demands and recognizes the
importance of cyber hygiene in preventing or mitigating such attacks. OFAC has also updated
the Advisory to emphasize the importance of improving cybersecurity practices and reporting
to, and cooperating with, appropriate U.S. government agencies in the event of a
ransomware attack. Such reporting, as the Advisory notes, is essential for U.S. government
agencies, including law enforcement, to understand and counter ransomware attacks and
malicious cyber actors.
OFAC strongly encourages victims and related companies to report these incidents to and
fully cooperate with law enforcement as soon as possible to avail themselves of OFAC’s
significant mitigation related to OFAC enforcement matters and receive voluntary selfdisclosure credit in the event a sanctions nexus is later determined.

ADDITIONAL AUTHORITIES
FinCEN, in addition to the guidance and enforcement activities above, has also engaged with
industry, law enforcement, and others on the ransomware threat through the FinCEN
Exchange public-private partnership. FinCEN held a first Exchange on ransomware in
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November 2020 and a second Exchange in August 2021. FinCEN is taking additional action
under its authorities to collect information relating to ransomware payments.

INTERNATIONAL COOPERATION AND IMPORTANCE OF
AML/CF T MEASURES F OR VIRTUAL CURRENCIES AND
SERVICE PROVIDERS
Countering ransomware benefits from close collaboration with international partners. At the
Group of Seven (G7) meeting in June, participants committed to working together to urgently
address the escalating shared threat from criminal ransomware networks. The G7 is
considering the risks surrounding ransomware, including potential impacts to the finance
sector. For example, the G7 Cyber Expert Group (CEG), co-chaired by Treasury and Bank of
England, met on September 1 and September 14, 2021 to discuss ransomware, which
remains a grave concern given the number and breadth of ransomware attacks across
industry sectors. The participants considered the e ects of ransomware attacks on the
financial services sector, as well as the broader economy, and explored ways to help improve
overall security and resilience against malicious cyber activity.
Given the illicit finance risk that virtual assets pose, including ransomware-related money
laundering, in June 2019 the Financial Action Task Force (FATF) amended its standards to
require all countries to regulate and supervise virtual asset service providers (VASPs),
including exchanges, and to mitigate against such risks when engaging in virtual asset
transactions. Among other things, countries are expected to impose customer due diligence
(CDD) requirements, and suspicious transaction reporting obligations across VASPs, which
can help inhibit cybercriminals’ exploitation of virtual assets while supporting investigations
into these illicit finance activities. Because profit-motivated cybercriminals must launder
their misappropriated funds, AML/CFT regimens are a critical chokepoint in countering and
deterring this criminal activity. This magnifies the need for all countries to e ectively and
expeditiously implement and enforce the FATF’s standards on virtual assets and VASPs. The
United States is committed to continued work at the FATF and with other countries to
implement the FATF standards, and we welcome the FATF’s ongoing work on this issue.
Click here to view identifying information on the entity designated today.
Click here for OFAC’s Frequently Asked Questions on Virtual Currency.

F OR MORE INF ORMATION ON RANSOMW ARE
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Please visit StopRansomware.gov, a one-stop resource for individuals and organizations of
all sizes to reduce their risk of ransomware attacks and improve their cybersecurity
resilience. This webpage brings together tools and resources from multiple federal
government agencies under one online platform. Learn more about how ransomware works,
how to protect yourself, how to report an incident, and how to request technical assistance.
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