COVD-19 Vaccine Fraud

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/


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