The Treasury Department urged financial institutions to be on alert for malicious or fraudulent transactions, and to notify FinCEN of any potential delays submitting Suspicious Activity Reports ("SARs") and other mandatory Bank Secrecy Act ("BSA") filings.
FinCEN likened the current climate around the coronavirus pandemic to that of a natural disaster in which criminal actors seek opportunities to prey on vulnerable firms and investors with disaster relief schemes involving benefits fraud, charities fraud, and cyber-related fraud. FinCEN identified several emerging trends of illicit behavior connected to COVID-19, including:
Bad actors who impersonate government agencies or international organizations to solicit donations, steal personal information or spread malware (imposter scams);
Offers of products or services by publicly-traded companies with the false claim of being able to defend against or cure COVID-19 (investment scams);
Sales of unapproved or misbranded products that falsely claim to protect a person's health against COVID-19, such as certain facemasks (product scams); and
Insider trading related to COVID-19.
FinCEN also encouraged firms to actively monitor public statements, warning letters, and other intelligence provided by the Federal Trade Commission, the Food and Drug Administration, and other relevant functional regulators for the most updated information on these threats.