In case you missed it, FinCEN issued a Notice alerting institutions about potential fraud related to COVID-19 vaccines on December 28th. Such fraud might include trying to sell unapproved/illegally marketed/counterfeit vaccines and/or the illegal diversion of legitimate vaccines. There have already been offers to expedite vaccine delivery in exchange for a fee and ransomware targeting vaccine research. Institutions should be on the lookout for fraud related to developing, distributing and/or administering COVID-19 vaccines.
Institutions that file SARs related to vaccine-related scams and cyberattacks should:
- Note “FIN-2020-NTC4” in Field 2 (i.e., Filing Institution Note to FinCEN) and the narrative;
- Select Field 34(z) (i.e., Fraud – Other); and,
- Indicate vaccine scam or vaccine ransomware, as applicable, in SAR Field 34(z)
Further details should be provided in the narrative such as, how the victim was contacted and/or how the victim provided/tried to provide payment information, if known. In addition, you should provide any information on IP addresses and/or phone numbers. Institutions should also refer to the “Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments” and the “Notice Related to the Coronavirus Disease 2019 (COVID-19)”, as applicable.
Find more BSA Information here – https://www.bankerscompliance.com/regulations-we-cover/the-bank-secrecy-act-bsa/
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!