InfoBytes Blog
FinCEN advisory warns of Covid-19 scams and money-mule schemes
On July 7, the Financial Crimes Enforcement Network (FinCEN) issued an advisory alerting financial institutions to potential indicators of Covid-19 imposter scams and money mule schemes (where actors impersonate federal government agencies, international organizations, and charities). The advisory outlines numerous red flag indicators and examples of these types of schemes in order to assist financial institutions in detecting, preventing, and reporting suspicious transactions. FinCEN emphasizes that “no single financial red flag indicator is necessarily indicative of illicit or suspicious activity,” and encourages financial institutions to consider additional contextual information, such as a customer’s historical financial activity and whether a customer exhibits multiple indicators, before making a determination that a transaction is suspicious or otherwise indicative of a potentially fraudulent Covid-19-related activity. FinCEN further advises financial institutions—in line with their risk-based approach to Bank Secrecy Act compliance—to perform additional inquiries and conduct investigations as necessary.