COVID-19 Fraud Alerts

Did you know that the Federal Trade Commission received more than 2.2 million fraud reports with losses of almost $3.3 billion in 2020?

FinCEN has published a number of Advisories and Notices related to COVID-19 fraud activity for financial institutions. For your convenience, we have listed these below.
This advisory provides financial red flag indicators of COVID-19 health insurance- and health care-related fraud activity and includes SAR instruction related to this type of fraud.
This advisory contains descriptions of COVID-19-related UI fraud, associated financial red flag indicators, and information on reporting suspicious activity.
This advisory provides information on: (1) the role of financial intermediaries in the processing of ransomware payments; (2) trends and typologies of ransomware and associated payments; (3) ransomware related financial red flag indicators; and (4) reporting and sharing information related to ransomware attacks.
This advisory is intended to aid financial institutions in detecting, preventing, and reporting potential COVID-19-related criminal activity.
This advisory contains descriptions of imposter scams and money mule schemes, financial red flag indicators for both, and information on reporting suspicious activity.
This advisory contains descriptions of COVID-19-related medical scams, case studies, red flags, and information on reporting suspicious activity.
This notice alerts financial institutions about the potential for fraud, ransomware attacks, or similar types of criminal activity related to COVID-19 vaccines and their distribution. It also provides specific instructions for filing Suspicious Activity Reports (SARs) regarding such suspicious activity related to COVID-19 vaccines and their distribution.
This notice contains pertinent information regarding reporting COVID-19-related criminal and suspicious activity and reminds financial institutions of certain Bank Secrecy Act (BSA) obligations.
This notice updates the Financial Crimes Enforcement Network’s (FinCEN’s) March 16, 2020 COVID-19 Notice, provides additional information to assist financial institutions in complying with their Bank Secrecy Act (BSA) obligations during the COVID-19 pandemic, and announces a direct contact mechanism for urgent COVID-19-related issues.
This notice 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. FinCEN also advises financial institutions to remain alert about malicious or fraudulent transactions similar to those that occur in the wake of natural disasters.
Paycheck Protection Program
Added FAQs regarding Second Draw PPP loans.
FAQs explaining the requirements under the Bank Secrecy Act (BSA), and how lenders can meet those requirements when issuing a PPP loan.

Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.

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