FinCEN Advisory FIN-2020-A003 — COVID-19 Imposter Scams & Money Mule Schemes (July 7, 2020)
Summary
FinCEN Advisory FIN-2020-A003, dated July 7, 2020, alerts financial institutions to imposter scams and money mule activity, two forms of consumer fraud observed during the COVID-19 pandemic. It describes imposters posing as officials or representatives of the IRS, the CDC, the World Health Organization, charities and contact tracers to obtain payments or personal information, often around Economic Impact Payments. It defines unwitting, witting and complicit money mules and notes good-Samaritan, romance and work-from-home recruiting, as well as money mules used against unemployment insurance programs. It lists financial red flag indicators for both kinds of fraud. FinCEN asks institutions to include the key term COVID19 MM FIN-2020-A003 in SAR field 2 and the narrative and to select SAR field 34(z) (Fraud - other).
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FIN-2020-A003 July 7, 2020
Advisory on Imposter Scams and Money Mule Schemes
Related to Coronavirus Disease 2019 (COVID-19)
Detecting, preventing, and reporting consumer fraud and other illicit activity related
to COVID-19 is critical to our national security, safeguarding legitimate relief efforts,
and protecting innocent people from harm.
This Advisory should be shared with: Introduction
• Chief Executive Officers The Financial Crimes Enforcement Network (FinCEN)
• Chief Operating Officers is issuing this advisory to alert financial institutions
to potential indicators of imposter scams and money
• Chief Compliance Officers
mule schemes, which are two forms of consumer fraud
• Chief Risk Officers
observed during the COVID-19 pandemic. Many illicit
• AML/BSA Departments actors are engaged in fraudulent schemes that exploit
• Legal Departments vulnerabilities created by the pandemic. This advisory
• Cyber and Security Departments contains descriptions of imposter scams and money
mule schemes, financial red flag indicators for both, and
• Customer Service Agents
information on reporting suspicious activity.
• Bank Tellers
This advisory is intended to aid financial institutions in
detecting, preventing, and reporting potential COVID-
SAR Filing Request: 19-related criminal activity. This advisory is based on
FinCEN requests financial institutions FinCEN’s analysis of COVID-19-related information
reference this advisory in SAR field obtained from Bank Secrecy Act (BSA) data, open source
2 (Filing Institution Note to FinCEN) reporting, and law enforcement partners. FinCEN
and the narrative by including the will issue COVID-19-related information to financial
following key term: “COVID19 MM institutions to help enhance their efforts to detect, prevent,
FIN-2020-A003” and select SAR field and report suspected illicit activity on its website at
34(z) (Fraud - other). Additional https://www.fincen.gov/coronavirus, which also contains
guidance for filing SARs appears information on registering to receive FinCEN Updates.
near the end of this advisory.
1
F I N C E N A D V I S O R Y
Financial Red Flag Indicators of COVID-19
Imposter Scams and Money Mule Schemes
Consumer frauds include imposter scams and money mule schemes, where actors deceive victims
by impersonating federal government agencies, international organizations, or charities. FinCEN
identified the financial red flag indicators described below to alert financial institutions to these
frauds and to assist financial institutions in detecting, preventing, and reporting suspicious
transactions associated with the COVID-19 pandemic.
As no single financial red flag indicator is necessarily indicative of illicit or suspicious activity,
financial institutions should consider additional contextual information and the surrounding facts
and circumstances, such as a customer’s historical financial activity, whether the transactions are
in line with prevailing business practices, and whether the customer exhibits multiple indicators,
before determining if a transaction is suspicious or otherwise indicative of potentially fraudulent
COVID-19-related activities. In line with their risk-based approach to compliance with the BSA,
financial institutions are also encouraged to perform additional inquiries and investigations where
appropriate. Additionally, some of the financial red flag indicators outlined below may apply to
multiple COVID-19-related fraudulent activities.
Imposter Scams
In imposter scams, criminals impersonate organizations such as government agencies, non-profit
groups, universities, or charities to offer fraudulent services or otherwise defraud victims. While
imposter scams can take multiple forms, the basic methodology involves an actor (1) contacting
a target under the false pretense of representing an official organization, and (2) coercing or
convincing the target to provide funds or valuable information, engage in behavior that causes the
target’s computer to be infected with malware, or spread disinformation.1 In the case of schemes
connected to COVID-19, imposters may pose as officials or representatives from the Internal
Revenue Service (IRS),2 the Centers for Disease Control and Prevention (CDC),3 the World Health
Organization (WHO), other healthcare or non-profit groups, and academic institutions.4
1. See Federal Trade Commission (FTC) Business Blog, “Seven Coronavirus Scams Targeting Your Business,” (March 25,
2020).
2. For information on IRS imposter scams in general, see FTC’s “IRS Imposter Scams Infographic,” (January 2020).
3. See Federal Bureau of Investigation (FBI) Internet Crime Complaint Center (IC3) Public Service Announcement “FBI
Sees Rise in Fraud Schemes Related to the Coronavirus (COVID-19) Pandemic,” (March 20, 2020).
4. FTC maintains links to resources concerning scams and the current trends it has observed. See FTC’s “Coronavirus
Advice for Consumers.”
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F I N C E N A D V I S O R Y
Illicit actors can use imposter scams to defraud and deceive the vulnerable, including the elderly
and unemployed, through the solicitation of payments (such as digital payments and virtual
currency), donations, or personal information via email, robocalls, text messages,5 or other
communication methods. For example, an imposter may contact potential victims by phone, email,
or text to imply that the victim must verify personal information or send payments to scammers in
return for COVID-19-related stimulus payments or benefits, including Economic Impact Payments
(EIP)6 under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.7 Another instance
includes imposters contacting victims and posing as government or health care representatives
engaged in COVID-19 contact tracing activities, implying that a victim must share personal or
financial information as part of contact tracing efforts.8 Multiple examples include phishing
schemes, where imposters send communications appearing to come from legitimate sources, to
collect victims’ personal and financial data and potentially infect their devices by convincing the
target to download a malicious attachment or click malicious links.9
Scammers may also impersonate legitimate charities or create sham charities, taking advantage of
the generosity of the public and embezzling donations intended for COVID-19 response efforts.10
5. For information about COVID-19-related imposter scams conducted by text messages and phone calls, see the Federal
Communications Commission (FCC), “COVID-19 Consumer Warnings and Safety Tips,” (May 20, 2020). The FTC
and the FCC have sent warning letters to multiple Voice over Internet Protocol (VoIP) service providers for allegedly
routing illegal pandemic-related scam telemarketing or robocalls. See FTC Press Release, “FTC and FCC Send
Joint Letters to Additional VoIP Providers Warning against ‘Routing and Transmitting’ Illegal Coronavirus-related
Robocalls,” (May 20, 2020).
6. EIP may take the form of Automated Clearing House (ACH) deposits, U.S. Treasury checks, or prepaid debit cards.
See U.S. Department of the Treasury (Treasury) Press Release “Treasury is Delivering Millions of Economic Impact
Payments by Prepaid Debit Card,” (May 18, 2020).
7. The FTC, the IRS, and the Treasury Inspector General for Tax Administration (TIGTA) each published information
about imposter scams, particularly as they relate to EIP. See FTC Blog, “Want to Get Your Coronavirus Relief Check?
Scammers do too,” (April 1, 2020) and “Coronavirus Checks: Flattening the Scam Curve,” (April 8, 2020); IRS News
Release, “IRS Issues Warning About Coronavirus-related Scams; Watch Out For Schemes Tied To Economic Impact
Payments,” (April 2, 2020) and the IRS’s Economic Impact Payment Information Center, (April 8, 2020); and TIGTA
Press Release, “TIGTA Urges Taxpayers to “Be On High Alert” For Coronavirus Relief Payment Scams,” (April 7, 2020).
8. See Department of Justice (DOJ) Press Release “U.S. Attorney Warns Public of COVID-19 Contact Tracing Frauds,”
(May 28, 2020).
9. See Department of Homeland Security (DHS) Cybersecurity and Infrastructure Security Agency (CISA) and the
United Kingdom’s (U.K.) National Cyber Security Centre (NCSC) Alert, “COVID-19 Exploited by Malicious
Cyber Actors” (April 8, 2020); and DHS, “Common Scams: Know How to Spot a Fake.” Additionally, see WHO
Cybersecurity, “Beware of Criminals Pretending to be WHO,” (April 2020). See also FTC Blog, “COVID-19 Scams
Targeting College Students,” (May 27, 2020); and DOJ Press Release, “Federal Law Enforcement Encourages the
Public to Remain Vigilant to Covid-19 Scams,” (April 22, 2020).
10. Multiple U.S. Attorneys’ Offices (USAOs) warn of criminals who may seek to exploit legitimate relief efforts for their
own illicit gain by soliciting donations to sham charities or crowdfunding sites. See USAO for the Southern District of
Georgia, “U.S. Attorney Warns of Coronavirus Scams Targeting Vulnerable Victims,” (March 25, 2020); USAO for the
Eastern District of Oklahoma, “Department of Justice Requests Citizens be Aware of And Report COVID-19 Fraud,”
(March 24, 2020); and USAO for the Middle District of Tennessee, “U.S. Attorney and FBI Urge the Public to Report
Suspected Fraud Related to Tornado Destruction and COVID-19,” (March 23, 2020). Additionally, the U.S. Securities
and Exchange Commission (SEC) noted the potential for charity investment frauds, where actors falsely claim that
investments will provide financial support or medical treatment to people in need, with the money instead stolen. See
SEC Investor Alerts and Bulletins, “Frauds Targeting Main Street Investors -- Investor Alert,” (April 10, 2020). See also
FTC’s information to avoid charity scams, “Make Your Coronavirus Donations Count,” (May 5, 2020).
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F I N C E N A D V I S O R Y
Criminals often use social media accounts, door-to-door collections, flyers, mailings, telephone
and robocalls, text messages, websites, and emails mimicking legitimate charities and non-profits
to defraud the public. These operations may include words like “relief,” “fund,” “donation,” and
“foundation” in their titles to give the illusion that they are a legitimate organization.11
Given that many scammers may be targeting customers as opposed to financial institutions
directly, financial institutions, when interacting with their customers, should remain on the alert
for potential suspicious activities. Financial red flag indicators of imposter scams may include:
A customer indicating that a person claiming to represent a government agency contacted
him or her by phone, email, text message, or social media asking for personal or bank account
information to verify, process, or expedite EIPs, unemployment insurance, or other benefits.
In particular, be alert to communications emphasizing “stimulus check” or “stimulus
payment” in solicitations to the public, sometimes claiming that the fraudulent entity can
expedite the “stimulus check” or other government payment on behalf of the beneficiary for a
fee paid by gift card or prepaid card.
Email correspondence that contains subject lines that government or industry have identified
as being associated with phishing campaigns, or that contains embedded links or webpage
addresses for purported COVID-19 resources that have irregular URLs (e.g., slight variations
in domain extensions like “.com,” “.org,” and “.us”). Examples of U.S. government-identified
COVID-19 phishing email subject lines include “2020 Coronavirus Updates,” “Coronavirus
Updates,” “2019-nCov: New confirmed cases in your City,” and “2019-nCov: Coronavirus
outbreak in your city (Emergency).”
11. See FTC, “How to Donate Wisely and Avoid Charity Scams.”
12. For more information on EIPs, visit IRS, “Economic Impact Payment Information Center,” (June 30, 2020).
13. See DHS CISA and U.K. NCSC Alert, “COVID-19 Exploited by Malicious Cyber Actors,” (April 8, 2020).
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F I N C E N A D V I S O R Y
Money Mule Schemes
A money mule is “a person who transfers illegally acquired money on behalf of or at the direction
of another.”14 Money mule schemes, including those related to the COVID-19 pandemic, span the
spectrum of using unwitting, witting, or complicit money mules.15 An unwitting or unknowing
money mule is an individual who is “unaware that he or she is part of a larger criminal scheme.” The
individual is motivated by his/her trust in the actual romance, job position or proposition.16 A witting
money mule is an individual who “chooses to ignore obvious red flags or acts willfully blind to his/
her money movement activity.” The individual is motivated by financial gain or an unwillingness
to acknowledge his/her role.17 A complicit money mule is an individual who is “aware of his/her
role as a money mule and is complicit in the larger criminal scheme.” The individual is motivated
by financial gain or loyalty to a criminal group.18 During the COVID-19 pandemic, U.S. authorities
14. See FBI, “Money Mule Awareness” (July 2019). For more information on money mules in general, see FinCEN,
“Updated Advisory on Email Compromise Fraud Schemes Targeting Vulnerable Business Processes,” (July 16, 2019);
“FinCEN Analysis: Bank Secrecy Act Reports Filed by Financial Institutions Help Protect Elders from Fraud and Theft
of Their Assets,” (December 4, 2019); and DOJ, “Justice Department Announces Landmark Money Mule Initiative,”
(December 4, 2019).
15. For more information about unwitting, witting, and complicit individuals involved in money mule scams, see FBI,
“Money Mule Awareness” (July 2019).
16. For examples of how an unwitting money mule is recruited and used, see id., p. 4.
17. For examples of how a witting money mule is recruited and used, see id., p. 5.
18. For examples of how a complicit money mule is recruited and used, see id.
5
F I N C E N A D V I S O R Y
have detected recruiters using money mule schemes, such as good-Samaritan, romance, and work-
from-home schemes.19 U.S. authorities also have identified criminals using money mules to exploit
unemployment insurance programs during the COVID-19 pandemic.20
Financial red flag indicators of COVID-19 money mule schemes may include:
19. The FBI has released information on how criminals are taking advantage of the COVID-19 pandemic to steal money,
access personal and financial information, and use individuals as money mules. See FBI Press Release, “FBI Warns
of Money Mule Schemes Exploiting the COVID-19 Pandemic,” (April 6, 2020). In work-from-home schemes, for
example, COVID-19 money mule recruiters, under a false charity or company label, may approach targets with a
seemingly legitimate offer of employment under the pretense of work-from-home jobs, often through internet or
social media advertisements, emails, or text messages. Once the target accepts the “employment,” he or she receives
instructions to move funds through accounts or to set up a new account in the target’s name for the “business.” The
target (i.e., the money mule) earns money by taking a percentage of the funds that he or she helps to transfer per the
instructions of the “employer.” For more information on fraudulent job offers, see FTC Blog, “Looking for work after
Coronavirus layoffs?,” (April 13, 2020).
20. See Washington State Employment Security Department, “Statement from Commissioner Suzi LeVine on the rise in
unemployment imposter fraud attempts,” (May 14, 2020) and “Update on imposter fraud from Commissioner Suzi
LeVine,” (May 18, 2020).
6
F I N C E N A D V I S O R Y
a. U.S. Service member who is reportedly stationed abroad;
b. U.S. citizen working or traveling abroad; or
c. U.S. citizen quarantined abroad.
Information on Reporting Suspicious Activity
Suspicious Activity Report (SAR) Filing Instructions
SAR reporting, in conjunction with effective implementation of due diligence requirements by
financial institutions, is crucial to identifying and stopping financial crimes, including those
related to the COVID-19 pandemic. Financial institutions should provide all pertinent and
available information in the SAR and narrative. Adherence to the filing instructions below will
improve FinCEN’s and law enforcement’s abilities to effectively identify actionable SARs using
the FinCEN Query system and pull information to support COVID-19- related investigations.
7
F I N C E N A D V I S O R Y
• FinCEN requests that financial institutions reference this advisory by including the key term
“COVID19 MM FIN-2020-A003” in SAR field 2 (Filing Institution Note to FinCEN) and the
narrative to indicate a connection between the suspicious activity being reported and the
activities highlighted 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., imposter scam or money mule scheme) in SAR field
34(z). In addition, FinCEN encourages financial institutions to report certain types of
imposter scams and money mule schemes using fields such as SAR field 34(l) (Fraud- Mass-
marketing), or SAR field 38(d) (Other Suspicious Activities- Elder Financial Exploitation), as
appropriate with the circumstances of the suspected activity.
• Please refer to FinCEN’s 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
Financial institutions should send questions or comments regarding the contents of this advisory 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.
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