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Financial Services Law Insights and Observations

FinCEN issues guidance on BSA reports

Federal Issues Covid-19 FinCEN Bank Secrecy Act Fraud Financial Crimes Of Interest to Non-US Persons

Federal Issues

On March 16, the Financial Crimes Enforcement Network (FinCEN) issued a release reminding financial institutions affected by Covid-19 to contact the agency and their functional regulator as soon as practicable if they anticipate delays in filing their Bank Secrecy Act reports. Financial institutions were also advised to be on alert for malicious or fraudulent transactions connected to Covid-19, particularly with respect to emerging trends such as imposter scams, investment scams, product scams, and insider trading. Financial institutions were also directed to review FinCEN advisory FIN-2017-A007—which discusses other relevant typologies, including benefits fraud, charities fraud, and cyber-related fraud—and encouraged to review guidance from their functional regulators as available.

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