John Zasada, Compliance Consulting Director, Financial Institutions Group
On Oct. 13, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2020-A007 to assist financial institutions in filing Suspicious Activity Reports (SARs) due to unemployment insurance fraud. FinCEN has noted a dramatic increase in COVID-19-related unemployment insurance fraud. The fraud takes various forms, including fictitious employer-employee fraud, employer-employee collusion fraud, misrepresentation of income fraud, insider fraud and identity-related fraud. FinCEN developed ten financial red flag indicators of unemployment insurance fraud.
If any of the red flags indicators are detected and it is determined a SAR should be filed, FinCEN requests financial institutions to reference this advisory by including the key term “COVID19 UNEMPLOYMENT INSURANCE FRAUD FIN-2020-A007” in SAR field 2. In addition, the SAR narrative should indicate a connection between the suspicious activity being reported and the activities highlighted in the advisory. Financial institutions should also select SAR field 34(z) (Fraud – other) as the suspicious activity type to indicate a connection between the suspicious activity being reported and COVID-19. If financial institutions detect unemployment fraud and are filing a SAR as a result, they should include the keywords “unemployment fraud” in SAR field 34(z).
If you have questions about this new advisory and its impact on your institution, contact Doeren Mayhew’s regulatory specialists.
This publication is distributed for informational purposes only, with the understanding that Doeren Mayhew is not rendering legal, accounting, or other professional opinions on specific facts for matters, and, accordingly, assumes no liability whatsoever in connection with its use. Should the reader have any questions regarding any of the news articles, it is recommended that a Doeren Mayhew representative be contacted.
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