FinCEN Issues Advisory on Medical Scams Necessitating SARs
On May 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an Advisory FIN-2020-A002 alerting financial institutions to medical scams and the need to file Suspicious Activity Reports (SARs) as a result. The advisory identifies several possible illicit activities financial institutions should be aware of, protect against and report in SARs if required. These illicit activities include medical-related frauds, such as fraudulent cures, tests, vaccines and services. The advisory contains specific red flags indicators of medical-related fraud, as well as case studies of detected medical-related frauds.
Financial institutions filing SARs for these frauds should enter “COVID19 FIN-2020-A002” in SAR field 2 (Filing Institution Note to FinCEN) and the narrative in order to indicate a connection between the suspicious activity being reported and the activities in this advisory. Financial institutions should also select SAR field 34(z) (Fraud – other) as the associated suspicious activity type to indicate a connection between the suspicious activity being reported and COVID-19. Financial institutions should include the type of fraud and/or name of the scam or product (e.g., product fraud – non-delivery scam) in SAR field 34(z).
FinCEN intends to issue several more advisories on financial crimes related to the COVID-19 pandemic. For more information on safeguarding your institution from fraud during the pandemic or keeping up on the needed SARs requirements, contact Doeren Mayhew today.
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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