Full text
1
FIN-2021-NTC1
February 24, 2021
Consolidated COVID-19 Suspicious Activity Report
Key Terms and Filing Instructions
The Financial Crimes Enforcement Network (FinCEN) is issuing this Notice to consolidate filing
instructions and key terms for fraudulent activities, crimes, and cyber and ransomware attacks
related to Coronavirus Disease 2019 (COVID-19), and to remind financial institutions of recent
updates to FinCEN guidance concerning Section 314(b). FinCEN has published a series of
advisories and notices on COVID-19-related threats to assist financial institutions with the filing of
suspicious activity reports (SARs) involving such threats. In this Notice, FinCEN further requests
that financial institutions consult the tables below when filing SARs for COVID-19-related activity.
Table 1 contains key terms and instructions related to government programs. Table 2 contains
a summary of the key terms and instructions for COVID-19-related activities that are not tied to
specific government programs. Table 3 provides a list of additional FinCEN’s COVID-19-related
publications. Financial institutions that follow the instructions set forth below will assist FinCEN,
law enforcement, financial regulators, and other relevant government agencies in identifying and
utilizing the information submitted in COVID-19-related SARs.
Financial institutions should consult previously published advisories and notices for additional
SAR filing instructions related to the advisories and notices included below. If financial institutions
wish to cite more than one advisory, then they should use only the FinCEN identification numbers
(FINs) listed in the tables below in Field 2, and provide the full references in the SAR narrative.
FinCEN requests that filers be as specific as possible in their SAR filings. For instance, if the SAR
addresses a government program, FinCEN requests that filers use program-specific keywords, as
detailed in the keyword columns in Table 1 below, and avoid relying on generalized key terms,
such as “stimulus,” “CARES Act,” or “benefit.” Doing so will expedite identification of relevant
SARs for appropriate investigative, analytical, supervisory, and other authorized purposes.
F I N C E N N O T I C E
2
Table 1: COVID-19 Government Programs
Government
Program
Keyword(s)
for Suspicious
Activity and
narrative
Field 2 (Note to
FinCEN)
Suspicious
Activity Field(s)
32-42
Economic Injury
Disaster Loan (EIDL)
Program1
Economic injury
disaster
COVID19 EIDL
FUNDS FRAUD2
34(z) (Fraud - other)
Economic Impact
Payments (EIP)3
Economic impact
payment
FIN-2021-A002
34(z) (Fraud - other)
Paycheck Protection
Program (PPP)4
Paycheck protection
FIN-2021-NTC1
34(z) (Fraud - other)
State Unemployment
Insurance5
Unemployment
COVID19
UNEMPLOYMENT
INSURANCE FRAUD
FIN-2020-A0076
34(z) (Fraud - other)
Pandemic
Unemployment
Assistance
Unemployment
COVID19
UNEMPLOYMENT
INSURANCE FRAUD
FIN-2020-A0077
34(z) (Fraud - other)
Main Street Lending8
FED MSL
FIN-2021-NTC1
34(z) (Fraud - other)
1.
For more information regarding this loan program, please visit U.S. Small Business Administration (SBA), Economic
Injury Disaster Loans.
2.
FinCEN News, “Prepared Remarks of FinCEN Director Kenneth A. Blanco, delivered virtually at the ACAMS AML
Conference,” (September 29, 2020).
3.
For more information about EIPs, please visit Internal Revenue Service (IRS), Economic Impact Payment Information
Center.
4.
For more information regarding the PPP, please visit SBA, Paycheck Protection Program.
5.
For more information about COVID-19-related unemployment insurance programs and relief, please visit the U.S.
Department of Labor, Unemployment Insurance Relief During COVID-19 Outbreak.
6.
FinCEN Advisory, FIN-2020-A007, “Advisory on Unemployment Insurance Fraud During the Coronavirus Disease
2019 (COVID-19) Pandemic,” (October 13, 2020).
7.
Id.
8.
For more information regarding the Main Street Lending Program, please visit Board of Governors of the Federal
Reserve System, Main Street Lending Program.
F I N C E N N O T I C E
3
Table 2: Other COVID-19-related Crimes and Frauds
Potential Fraud or
Crime
Keyword(s)
for Suspicious
Activity and
narrative
Field 2 (Note to
FinCEN)
Suspicious
Activity Field(s)
32-42
Cyber crime
BEC fraud, EAC
fraud, and others as
warranted
COVID19-CYBER
FIN-2020-A0059
34 (z) (Fraud –other)
for BEC, EAC; 38 (a)
account takeover; 42
(a), (b), and/or (z), as
appropriate (noting
the (z) “other” box
the COVID-19 cyber
event); 44 (a) through
(j) cyber event
indicators, as relevant
and available
Health insurance and
health care
Kickbacks, services
not provided, billing
schemes, and others
as warranted
FIN-2021-A00110
34(g) (Health care
– public or private
health insurance)
Medical products
Fraudulent products,
non-delivery scam,
price gouging,
hoarding
COVID19 FIN-2020-
A00211
34(z) (Fraud - other)
Vaccine-related scams
and cyber crimes
Vaccine scam or
vaccine ransomware
FIN-2020-NTC412
34(z) (Fraud - other)
Money mule and
imposter scams
Imposter, money
mule scams
COVID19 MM FIN-
2020-A00313
34(z) (Fraud - other)
9.
FinCEN Advisory, FIN-2020-A005, “Advisory on Cybercrime and Cyber-Enabled Crime Exploiting the Coronavirus
Disease 2019 (COVID-19) Pandemic,” (July 30, 2020).
10. FinCEN Advisory, FIN-2021-A001, “Advisory on COVID-19 Health Insurance- and Health Care-Related Fraud,”
(February 2, 2021).
11. FinCEN Advisory, FIN-2020-A002, “Advisory on Medical Scams Related to the Coronavirus Disease 2019
(COVID-19),” (May 18, 2020).
12. FinCEN Notice, FIN-2020-NTC4, “FinCEN Asks Financial Institutions to Stay Alert to COVID-19 Vaccine-Related
Scams and Cyberattacks,” (December 28, 2020).
13. FinCEN Advisory, FIN-2020-A003, “Advisory on Imposter Scams and Money Mule Schemes Related to Coronavirus
Disease 2019 (COVID-19),” (July 7, 2020).
F I N C E N N O T I C E
4
Table 3: Additional FinCEN COVID-19-related Publications
Field 2 (Note to
FinCEN)
Title
February 1, 2021 FAQs
Paycheck Protection Program Frequently Asked Questions
(FAQs)
FIN-2020-NTC3
Notice Related to the Coronavirus Disease 2019 (COVID-19)
FIN-2020-NTC2
The Financial Crimes Enforcement Network Provides Further
Information to Financial Institutions in Response to the
Coronavirus Disease 2019 (COVID-19) Pandemic
FIN-2020-NTC1
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
Updates to Section 314(b) Fact Sheet
and Information Sharing Documents
FinCEN updated its USA PATRIOT Act Section 314(b) Fact Sheet in December 2020. The Fact Sheet,
which addresses safe harbor protections in connection with certain private-sector information
sharing, supersedes the material concerning information sharing provided in FinCEN’s May 2020
Notice Related to the Coronavirus Disease 2019 (COVID-19).
For Further Information
Additional COVID-19-related information, including COVID-19-related advisories and notices,
is located 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.