FinCEN says FIs should tell regulators if they expect delays in BSA report filing due to coronavirus

Treasury’s financial crimes unit on Monday urged financial institutions affected by the coronarivus (COVID-19) to tell its office as well as the institutions’ functional regulators “as soon as practicable” if they have any concern about potential delays in their ability to file required Bank Secrecy Act (BSA) reports.

In a release, the Financial Crimes Enforcement Network (FinCEN) also encouraged such institutions to keep it and regulators informed as circumstances change.

FinCEN said institutions seeking to contact its office should call FinCEN’s Regulatory Support Section (RSS) at 1-800-949-2732 and select option 6, or e-mail to It said FinCEN’s RSS will continue to be available to support financial institutions for the duration of the COVID-19 pandemic.

The agency also advised institutions to remain alert about malicious or fraudulent transactions similar to those that occur in the wake of natural disasters. FinCEN is monitoring public reports and BSA reports of potential illicit behavior connected to COVID-19 and notes the following emerging trends:

  • 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.

FinCEN also directed institutions to FinCEN’s advisory, FIN-2017-A007 “Advisory to Financial Institutions Regarding Disaster-Related Fraud” (October 31, 2017), for descriptions of other relevant typologies, such as benefits fraud, charities fraud, and cyber-related fraud. For suspected suspicious transactions linked to COVID-19, along with checking the appropriate suspicious activity report-template (SAR-template) box(es) for certain typologies, FinCEN encourages financial institutions to enter “COVID19” in Field 2 of the SAR-template.

“Financial institutions are encouraged to review information from other relevant functional regulators as updates are available,” it stated. “FinCEN will continue to monitor this situation and will release updated information for financial institutions as appropriate.”

The Financial Crimes Enforcement Network (FinCEN) Encourages Financial Institutions to Communicate Concerns Related to the Coronavirus Disease 2019 (COVID-19) and to Remain Alert to Related Illicit Financial Activity