FinCEN Advises Financial Institutions to Note Suspicious Activity Related to COVID-19 in SAR Filings

As part of its duty to detect and deter financial crime, the Financial Crimes Enforcement Network (FinCEN) collects and analyzes information it receives from financial institutions in mandated regulatory filings, such as Suspicious Activity Reports (SARs). In so doing, FinCEN has been tracking and monitoring illicit activity and suspicious transactions involving COVID-19 as well as noting emerging trends related to the pandemic. As a result, FinCEN issued guidance last week advising financial institutions to remain alert to illicit financial activity and fraudulent transactions, including various scams and COVID-19-related insider trading. FinCEN further urged financial institutions to file SARs on suspicious activity involving COVID-19 and to specifically note “COVID19” in Field 2 on the SAR form. This information will enable FinCEN to more efficiently track and evaluate COVID-19-related schemes.

In addition, FinCEN requested that financial institutions contact FinCEN and their functional regulator if the financial institution expects potential delays in its ability to file required Bank Secrecy Act (BSA) reports as a result of any impact from COVID-19. In this regard, financial institutions can contact FinCEN’s Regulatory Support Section (RSS) at 1-800-949-2732 or send an e-mail to Financial institutions are also urged to keep FinCEN and their functional regulators informed if their circumstances change.

To read FinCEN's full announcement in response to COVID-19 and its related BSA reporting guidance, click here.

To read a blog post summarizing other official guidance regarding COVID-19-related fraud and financial crime, see here.

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