Ransomware in 2025: A Persistent Threat in a Shifting Landscape

Ransomware remains a top cybersecurity threat for financial institutions. Despite broader media focus on attacks in critical infrastructure and healthcare, banks, credit unions, and fintechs continue to face rising risk.

In 2025, the ransomware landscape has shifted: attack frequency is up, but ransom payments and media coverage are down. Understanding this contradiction is critical to building resilience, maintaining compliance, and protecting customer trust.

For community financial institutions, the focus must evolve. Defense strategies should now emphasize data extortion, reputational risk, and regulatory exposure—not just recovery from encryption events. NETBankAudit supports this shift by aligning threat response with governance, cyber maturity, and FFIEC frameworks.

This article outlines emerging ransomware trends, evolving tactics, and institutional responses for today’s compliance and security leaders.

The Changing Nature of Ransomware in 2025

Record Attack Volume, Fewer Payouts

Ransomware activity has hit new highs. BlackFog’s 2025 State of Ransomware QI reports over 590 victim disclosures in January 2025 and 886 in February—the most ever recorded in a single month. The rise is driven by ransomware-as-a-service (RaaS) models, which let low-skill affiliates deploy ready-made attack kits from criminal developers.

Yet, despite more attacks, fewer organizations are paying. Known ransomware revenue dropped from $1.25 billion in 2023 to $814 million in 2025—a 35% decline. Less than 25% of victims paid in Q4 2024, the lowest rate on record.

This drop is due to stronger preparation—not reduced threat. Many institutions now use segmented, restorable backups and improved disaster recovery processes to withstand extortion attempts. But the progress brings a new risk: overconfidence.

Less Coverage, Lower Priority

As attacks have grown more frequent, their shock value has faded. High-profile breaches like the Colonial Pipeline attack in 2021 once dominated headlines. Today, ransomware often flies under the radar.

Even attackers have noticed. As noted by BankInfoSecurity, some groups express frustration that data leak threats no longer draw press attention. This limits reputational damage and reduces pressure on victims.

Internally, the trend is just as dangerous. Executive risk committees are paying less attention. In some institutions, ransomware defense has taken a backseat to newer threats like AI misuse or nation-state actors. While these risks are valid, deprioritizing ransomware leaves financial institutions exposed to one of the most persistent threats they face.

Implications for Financial Institutions and Sector Risk

Ransomware and Regulatory Expectations

For financial institutions regulated under the Gramm-Leach-Bliley Act (GLBA), FFIEC IT Booklets, and related frameworks, ransomware remains a significant compliance concern. Even if the ransom is not paid, a ransomware attack may qualify as a notifiable incident under:

• The Computer-Security Incident Notification Rule for federally regulated banks and credit unions, requiring notification to regulators within 36 hours of a qualifying cyber event.
• State-level data breach laws, which may mandate notification to affected consumers if nonpublic personal information (NPI) is accessed or exfiltrated.
• SEC disclosure requirements for public companies under Regulation S-K and Form 8-K Item 1.05 (as of 2023), which mandate public disclosure of material cybersecurity incidents.

Institutions must also consider OFAC ransomware guidance, which warns that paying a ransom to a sanctioned entity (even under duress) may constitute a violation of U.S. law. This is particularly relevant given the geographic origins of many ransomware operators, including regions under U.S. sanctions. Before engaging in any ransom negotiations, financial institutions must consult legal counsel and ensure compliance with OFAC screening procedures.

Increased Focus on Data Theft and Dual Extortion

Historically, ransomware was characterized by file encryption and system denial, disrupting operations until payment was rendered. Today, however, many threat actors have shifted toward data exfiltration and extortion, sometimes skipping encryption entirely. Known as dual extortion, this tactic involves:

• Gaining unauthorized access to institutional systems
• Stealing sensitive files and customer data
• Threatening to publish or sell the stolen data if a ransom is not paid

This model complicates institutional response. Even if backups enable a clean system restoration, the reputational and regulatory implications of stolen data remain. Financial institutions must treat ransomware as both a business continuity and a privacy compliance issue. For example, if customer NPI, loan documentation, or ACH data is exposed, the institution must engage incident response counsel, notify affected individuals, and in some cases, report the incident to law enforcement and federal regulators.

NETBankAudit supports institutions by conducting readiness reviews that integrate ransomware-specific testing into broader GLBA/FFIEC cybersecurity assessment scopes, ensuring that both operational response and compliance requirements are addressed.

The Ransomware-as-a-Service (RaaS) Ecosystem and Threat Actor Turnover

Constant Rotation of Threat Actor Infrastructure

The operational model for ransomware has undergone significant professionalization. Today, most ransomware activity originates from RaaS ecosystems, in which a core group of developers licenses out malware payloads to independent affiliates in exchange for a share of ransom proceeds. This model has created a dynamic and fragmented threat landscape. Even when law enforcement disables a major group (as seen with LockBit in early 2024), affiliates often rebrand or move to new platforms within days.

This churn presents challenges for institutional threat intelligence and defense:

• Familiar names may disappear, but their tools and tactics remain
• Indicators of compromise (IOCs) must be updated regularly
• Attack signatures evolve rapidly through shared underground codebases

For CISOs and risk officers, this underscores the importance of monitoring behavioral attack patterns rather than relying solely on group names or known file hashes. Institutions must also track which ransomware groups are associated with sanctioned regions to avoid legal violations during incident handling.

Operational Resilience and Mitigation Strategies

Strengthening Business Continuity and Recovery Plans

Financial institutions must develop tested, documented, and board-approved plans for continuity of operations in the event of a ransomware incident. Key components include:

• Isolated and Immutable Backups: Backups must be segmented from the primary network and safeguarded from tampering. Immutable backups, such as write-once storage or air-gapped repositories, help ensure data integrity even if the network is compromised.
  
• Restoration Testing: Institutions should conduct quarterly restoration exercises to validate backup usability and recovery time objectives (RTOs). Restoration capabilities must be aligned with business impact analysis (BIA) results. According to the IBM Cost of a Data Breach Report, organizations that tested their incident response plans saved an average of $1.49 million per breach compared to those that did not.
  
• Minimum Viable Operations Framework: In a ransomware event, restoring full system functionality may take days. Institutions should predefine what constitutes minimum viable operations. Examples include processing deposits, honoring loan disbursements, and maintaining core ACH or wire systems.
  

Network Segmentation and Least-Privilege Access

Ransomware actors commonly rely on lateral movement post-initial intrusion. Once inside, they escalate privileges, disable defenses, and exfiltrate sensitive data. Effective mitigation requires:

• Internal Segmentation: Critical systems such as loan origination, online banking, and payment processing should be segmented from general administrative and user networks using VLANs, firewalls, or microsegmentation technologies.
  
• Zero-Trust Architecture Principles: Role-based access controls (RBAC), strong authentication (including phishing-resistant MFA), and device health checks can limit the ability of malware to spread.
  
• Privileged Account Management (PAM): Admin accounts must be tightly controlled, monitored, and rotated. Emergency access credentials should be vaulted and require dual-approval protocols during crisis events.

These measures significantly increase containment capacity and reduce the likelihood of operational disruption even if ransomware bypasses initial defenses.

Regulatory, Legal, and Executive Considerations

Executive Oversight and Strategic Planning

Leadership engagement is critical to effective ransomware response. Executive and board-level involvement must extend beyond annual risk summaries. Best practices include:

• Board-Approved Ransomware Response Policy: Institutions should define, in writing, their position on ransom payments, law enforcement engagement, and public communications. This policy must balance operational continuity, customer protection, and legal risk.
  
• Tabletop Exercises and Scenario Planning: At least annually, executive leadership and key department heads should participate in ransomware-specific tabletop exercises. Scenarios should test decision-making around data exposure, payment deliberations, operational impact, and third-party communications.
  
• Incident Decision Frameworks: Institutions should maintain predefined decision workflows for ransomware events. These frameworks clarify who is authorized to initiate system shutdowns, engage cyber counsel, approve communication to customers, or interact with extortionists (if allowed under legal counsel).

Boards are increasingly expected to demonstrate cybersecurity oversight, not merely awareness. A ransomware-specific appendix to existing business continuity or incident response plans can provide structure, demonstrate forethought, and reduce the burden during a real event.

Sector-Specific  Risks and Strategic Trends

Financial Services Institutions

Banks and credit unions are increasingly targeted not only for their customer data but also for their role as infrastructure operators. Threat actors may attempt to disrupt:

• ACH and wire transfers
• Core banking platforms
• Digital banking portals and authentication layers

Smaller institutions are especially vulnerable due to limited cybersecurity staffing and lower investment in segmentation or real-time monitoring tools. Ransomware recovery is also becoming more complex as multi-core systems and cloud integrations complicate restoration timelines.

NETBankAudit helps community institutions conduct ransomware resilience assessments that align with FFIEC’s Architecture, Infrastructure, and Operations Booklet, and assess weaknesses related to vendor platforms, hosted infrastructure, or remote support access.

Healthcare and Tech Services (as Third-Party Risk)

Financial institutions increasingly rely on technology vendors and service providers to deliver critical functions from loan servicing platforms to digital identity verification tools. Ransomware incidents affecting healthcare data aggregators, cloud-based fintech platforms, and other core technology vendors can trigger operational and reputational consequences for financial institutions, even if the institution itself was not directly attacked.

Vendor due diligence and supply chain security are essential components of a complete ransomware mitigation strategy. Institutions should require ransomware-specific disclosures and incident history as part of ongoing vendor risk reviews.

The NETBankAudit Advantage: Building Resilience Before the Crisis

Financial institutions that adopt a proactive, governance-aligned approach to ransomware preparedness will be best positioned to mitigate impact, meet regulatory expectations, and preserve customer confidence in the event of a breach. NETBankAudit supports these efforts through:

• GLBA/FFIEC-aligned ransomware resilience audits
• Tabletop facilitation and executive response training
• Policy reviews and incident response playbook development
• Technical control mapping against CIS Controls, NIST CSF, and CRI Profile standards
• Independent assessments of ransomware recovery readiness and regulatory posture

Whether your institution is seeking to validate its ransomware strategy, conduct a readiness review, or ensure documentation will withstand examination, NETBankAudit brings decades of focused experience serving the risk, security, and compliance needs of community financial institutions.

Contact NETBankAudit for Ransomware Readiness Support

The ransomware threat in 2025 is quieter, more fragmented, and more insidious than ever. Ensuring readiness now, before the next wave of attacks, is the most effective way to safeguard your customers, operations, and institutional integrity.

Contact NETBankAudit today to schedule a ransomware resilience review or discuss how our expert team can support your security and compliance roadmap.