FinCEN Issues New Advisory Related to COVID-19
In a post in March, we discussed FinCEN's guidance for financial institutions to remain vigilant during times of crisis and that there had been reports of criminals using the pandemic to turn innocent people into unwitting money mules. In an advisory yesterday, FinCEN identified 18 financial red flags that companies should be aware of, both for imposter scams and money mule schemes related to the pandemic. Here are some of the new red flags:
- Communications emphasizing “stimulus check” or “stimulus payment”
- Actual documents that appear to be a stimulus check or debit card but for less than the expected amount, with instructions to contact a fraudulent agency to receive the full amount
- Solicitations for donations to charities by persons who are either not associated with the charity they claim to represent or are collecting on behalf of a fraudulent charity
- The customer’s account receives unemployment insurance payments for numerous employees
- The customer has been asked to send/receive funds through their personal account for someone who claims to be a U.S. citizen who is quarantining abroad
The advisory provided guidance on filing SAR forms related to these red flags, such as including "COVID19 MM FIN-2020-A003" in the Filing Institution Note to FinCEN field and choosing "Fraud - other" for the suspicious activity type.