By now we are all feeling the effects that COVID-19 has had on our daily life, both personally and professionally. It can be unsettling not knowing what tomorrow will bring. On March 16, FinCEN put out an update regarding COVID-19 and Bank Secrecy Act (BSA) Compliance. Specifically, if a financial institution has been affected by COVID-19 and has a concern about their ability to file any BSA-required report, they should contact FinCEN and their regulator.
FinCEN also advised financial institutions to not let down their guard during this time. Institutions need to continue to be diligent and remain alert regarding potential scams, fraudulent transactions, and illicit behavior related to COVID-19. FinCEN noted to keep an eye out for the following:
Imposter Scams – Bad actors attempt to solicit donations, steal personal information, or distribute malware by impersonating government agencies (e.g., Centers for Disease Control and Prevention), international organizations (e.g., World Health Organization (WHO)), or healthcare organizations.
Investment Scams – The U.S. Securities and Exchange Commission (SEC) urged investors to be wary of COVID-19-related investment scams, such as promotions that falsely claim that the products or services of publicly traded companies can prevent, detect, or cure coronavirus.
Product Scams – The U.S. Federal Trade Commission (FTC) and U.S. Food and Drug Administration (FDA) have issued public statements and warning letters to companies selling unapproved or misbranded products that make false health claims pertaining to COVID-19. Additionally, FinCEN has received reports regarding fraudulent marketing of COVID-19-related supplies, such as certain facemasks.
Insider Trading – FinCEN has received reports regarding suspected COVID-19-related insider trading.
For any SAR filings related to COVID-19, FinCEN encourages putting “COVID19” in Field 2 of the SAR form.
While we’re on the topic of Bank Secrecy Act, we wanted to make you aware of our upcoming webinar, “BSA: Just for Operations”. Click on the video to listen to Kevin explain what this webinar is all about and why you need to attend.
We hope you’ll JOIN US on March 31, 2020!
Other Upcoming BSA/AML Webinars:
April 2nd – BSA for Lenders