The Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a statement on the coronavirus disease (COVID-19) and its effects on financial institutions. FinCEN requests financial institutions affected by the COVID-19 pandemic to contact FinCEN and their functional regulator as soon as practicable if a COVID-19-affected financial institution has concern about any potential delays in its ability to file required Bank Secrecy Act (BSA) reports.
Financial institutions are encouraged to keep FinCEN and their functional regulators informed as their circumstances change.
FinCEN also advises financial institutions to remain alert about malicious or fraudulent transactions similar to those that occur in the wake of natural disasters.
FinCEN is monitoring public reports and BSA reports of potential illicit behavior connected to COVID-19 and notes the following emerging trends:
FinCEN’s 2017 advisory, “Advisory to Financial Institutions Regarding Disaster-Related Fraud” (FIN-2017-A007) contans descriptions of other relevant typologies, such as benefits fraud, charities fraud, and cyber-related fraud.
For suspected suspicious transactions linked to COVID-19, along with checking the appropriate suspicious activity report-template (SAR-template) box(es) for certain typologies, FinCEN also encourages financial institutions to enter “COVID19” in Field 2 of the SAR-template.
Financial institutions are encouraged to review information from other relevant functional regulators as updates are available. FinCEN will continue to monitor this situation and will release updated information for financial institutions as appropriate.