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FIN-2020-NTC4
December 28, 2020
FinCEN Asks Financial Institutions to Stay Alert to
COVID-19 Vaccine-Related Scams and Cyberattacks
The Financial Crimes Enforcement Network (FinCEN) is issuing this Notice to alert financial
institutions about the potential for fraud, ransomware attacks, or similar types of criminal
activity related to COVID-19 vaccines and their distribution.1 As of December 28, 2020, the
U.S. Food and Drug Administration (FDA) has issued two emergency use authorizations for
COVID-19 vaccines in the United States.2 This Notice also provides specific instructions for
filing Suspicious Activity Reports (SARs) regarding such suspicious activity related to COVID-19
vaccines and their distribution.
COVID-19 vaccine fraud may include the sale of unapproved and illegally marketed vaccines,
the sale of counterfeit versions of approved vaccines, and illegal diversion of legitimate vaccines.3
Already, fraudsters have offered, for a fee, to provide potential victims with the vaccine sooner
than permitted under the applicable vaccine distribution plan.4
In addition, cybercriminals, including ransomware operators, will continue to exploit the
COVID-19 pandemic alongside legitimate efforts to develop, distribute, and administer vaccines.
FinCEN is aware of ransomware directly targeting vaccine research, and FinCEN asks financial
institutions to stay alert to ransomware targeting vaccine delivery operations as well as the
supply chains required to manufacture the vaccines. Financial institutions and their customers
should also be alert to phishing schemes luring victims with fraudulent information about
COVID-19 vaccines.
1.
For additional information, see FinCEN Advisory, FIN-2020-A002, “Advisory on Medical Scams Related to
the Coronavirus Disease 2019 (COVID-19),” (May 18, 2020); FinCEN Advisory, FIN-2020-A006, “Advisory on
Ransomware and the Use of the Financial System to Facilitate Ransom Payments,” (October 1, 2020); and FinCEN
Advisory, FIN-2020-A005, “Advisory on Cybercrime and Cyber-Enabled Crime Exploiting the Coronavirus Disease
2019 (COVID-19) Pandemic,” (July 30, 2020).
2.
For current information on COVID-19-related vaccines, see FDA “COVID-19 Vaccines.”
3.
See Federal Bureau of Investigation (FBI) Press Release, “Federal Agencies Warn of Emerging Fraud Schemes
Related to COVID-19 Vaccines” (December 21, 2020); FDA, “Beware of Fraudulent Coronavirus Tests, Vaccines
and Treatments,” (Last update, December 15, 2020); U.S. Department of Homeland Security (DHS), Immigration
and Customs Enforcement (ICE) News Release, “ICE Pivots to Combat COVID-19 Vaccine Fraud with Launch of
Operation Stolen Promise 2.0,” (November 30, 2020); INTERPOL News Release, “INTERPOL Warns of Organized
Crime Threat to COVID-19 Vaccines,” (December 2, 2020); and Europol Early Warning Notification, “Vaccine-related
Crime During the COVID-19 Pandemic,” (December 4, 2020).
4.
For more information about fraudsters targeting vaccine distribution in the United States, see FBI Press Release,
“Federal Agencies Warn of Emerging Fraud Schemes Related to COVID-19 Vaccines” (December 21, 2020); and
Federal Trade Commission, “COVID-19 Vaccines are in the Pipeline. Scammers Won’t be Far Behind,” (December 8,
2020).
F I N C E N N O T I C E
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Suspicious Activity Report (SAR) Filing Instructions
SAR reporting, in conjunction with effective implementation of Bank Secrecy Act (BSA) compliance
requirements by financial institutions, is crucial to identifying and stopping fraud, cybercrime,
and cyber-enabled crime, including those related to the COVID-19 vaccine. Financial institutions
should provide all pertinent information in the SAR.
• FinCEN requests that financial institutions reference “FIN-2020-NTC4” in SAR field 2 (Filing
Institution Note to FinCEN) and the narrative portion of the SAR to indicate a connection
between the suspicious activity being reported and the activities highlighted in this notice.
• 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., vaccine scam or vaccine ransomware) in SAR field 34(z).
• FinCEN requests that filers further detail the reported activity in the narrative portion of the SAR.
If the activity is suspected of being a scam, filers should provide known details about how the
scammers contacted the victim, how the victim provided or attempted to provide payment related
to the scam, and any other available details including data related to the financial transactions or
method of contact, such as Internet Protocol (IP) addresses and phone numbers. For guidance on
ransomware attacks, see FinCEN Advisory, FIN-2020-A006, “Advisory on Ransomware and the
Use of the Financial System to Facilitate Ransom Payments,” (October 1, 2020).
• Please refer to FinCEN’s May 2020 Notice Related to the Coronavirus Disease 2019 (COVID-19),
which contains information regarding reporting COVID-19-related crime, and reminds financial
institutions of certain BSA obligations
For Further Information
Additional COVID-19-related information, including advisories and notices, can be found on
FinCEN’s website at https://www.fincen.gov/coronavirus, which also contains information on how
to register for FinCEN Updates.
Questions or comments regarding the contents of this notice should be addressed to the FinCEN
Regulatory Support Section at frc@fincen.gov.
The mission of the Financial Crimes Enforcement Network is to safeguard
the financial system from illicit use, combat money laundering and its
related crimes including terrorism, and promote national security through
the strategic use of financial authorities and the collection, analysis, and
dissemination of financial intelligence.