COVID-19: Bank Secrecy Act Reporting Requirements and Suspicious Activity Reports
Bank Secrecy Act officers have discovered that the COVID-19 pandemic has spawned all manner of scams, price gouging, and even terrorist activities. FinCEN Advisories reveal a dizzying array of fraudulent transactions, all aimed at taking unfair advantage of Uncle Sam, the financial industry, and vulnerable Americans.
- Fraudulent cures, tests, vaccines, and other services
- Non-delivery scams
- Price gouging and hoarding of medical materials
- Imposter scams in which the bad guys pretend to be government officials, NGOs, universities, or legitimate charities
- Money-mule schemes, especially with unemployment compensation, in which one individual transfers ill-gotten money on behalf of another
- Bitcoin boondoggles on behalf of terrorist organizations like ISIS
The Bank Secrecy Act requires your financial institution to identify and report these growing illegal schemes in suspicious activity reports.
- How are BSA reporting obligations affected by COVID-19?
- What federal relief legislation has changed the requirements?
- What are some examples of suspicious activity reports related to the pandemic?
- What best practices should you follow for completing pandemic-related SARs?
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