In today's digital landscape, ransomware attacks pose a significant threat to organizations of all sizes. This document outlines a company's proactive measures to prepare for such an incident, including insurance coverage, backup strategies, and a thorough evaluation of workflows in the event of an attack. The focus is on the complexities involved in executing a ransomware payment, highlighting the necessary compliance with various regulations and the role of specialized teams in managing the situation effectively.
As ransomware attacks become increasingly sophisticated, organizations must adopt a comprehensive approach to mitigate risks and respond effectively. This document details the steps taken by a company to prepare for potential ransomware incidents, emphasizing the importance of insurance, backups, and a well-defined workflow. The evaluation reveals critical gaps in the payment execution process, which must be addressed to ensure a swift and compliant response.
- Negotiator verification and settlement: During a ransomware attack is critical to manage communication with attackers strategically, reduce ransom demands, and ensure legal compliance with TradeBP. They mitigate risks, protect the organization’s reputation, and allow internal teams to focus on recovery. Skilled negotiators also prevent costly mistakes, ensuring a professional and effective response.
- Incident Affiliation Screening: It is essential to screen the incident affiliation beyond just the wallet address to identify any sanctioned entities. This step is necessary for the Money Laundering Reporting Officer (MLRO) to authorize the payment.
- Facilitating Wire Transfers: The process of executing a ransomware payment begins with facilitating a wire transfer. This involves completing banking screenings to comply with the Financial Action Task Force (FATF) sanction list, which can take multiple working days.
- Crypto Payment Regulations: Holding cryptocurrency for payment necessitates adherence to the European Union's Markets in Crypto-Assets (MICA) travel rule or New York Department of Financial Services (NYDFS) regulations regarding crypto holder information transfer. Organizations must ensure they are compliant with these regulations to facilitate a legal transaction.
- Compliance with AML Laws: Anti-Money Laundering (AML) laws require organizations to report both the pre-intent of payment and post-payment activities to regulatory bodies such as the Securities and Exchange Commission (SEC), Federal Bureau of Investigation (FBI), FATF, and Financial Conduct Authority (FCA). This compliance is crucial to avoid legal repercussions.
- Payment Reporting: reporting ensures compliance with regulations by notifying authorities, verifying against sanction lists, documenting incidents, and conducting audits—essential steps to protect legal standing and build trust
To address the identified gaps in the ransomware payment execution process, the company has partnered with TradeBP to implement the CyberReady solution, which includes:
- Nine Hours End-to-End Payment Execution: Streamlining the payment process to ensure rapid execution within a defined timeframe.
- Negotiator Expert Communication: Engaging skilled negotiators to facilitate communication during the payment process.
- Banking KYB and Cyber Project Invoices: Preparing necessary banking Know Your Business (KYB) documentation and invoices while whitelisting both the company and TradeBP.
- BTC Ledger Provision: Providing a ledger with a specified amount of Bitcoin (BTC) for the payment exercise.
- Screening Reporting: Generating screening reports signed by an authorized MLRO in accordance with FATF guidelines.
- Regulatory Reporting: Executing reporting for both payment intent to Europol/Interpol and payment execution on TradeBP as the custodian
As ransomware threats continue to evolve, organizations must remain vigilant and prepared. By evaluating workflows and addressing compliance gaps in the payment execution process, the company can enhance its resilience against ransomware attacks. The collaboration with TradeBP through the CyberReady solution provides a structured approach to managing potential incidents, ensuring that the organization can respond swiftly and effectively while adhering to regulatory requirements.
