Scams come in all shapes and sizes. Sometimes scams give themselves away because they are poorly worded and badly formatted, which allows many to easily spot them as scams. Other times, however, scams can be very sophisticated and can fool even those who work in the tech industry or are looking for scams. In short, anyone can fall for a scam of one type or another.
Sadly, nearly any time something newsworthy happens, you can just about bet there will be a scam soon to follow. For example, COVID-19 has dominated the news headlines for almost an entire year with multiple scams popping up; the latest being e-mail and text message scams related to the vaccine. These are not the first vaccine scams we’ve seen, as vaccine scams have sort of been making their way around for a while, but we’re really starting to see the first wave of scams after the vaccine has been made publicly available. These scams commonly include information about being getting on a waiting list for early access to the vaccine, requests for payment for the vaccine to be shipped directly to the victim, and various advertisements attempting to have the victim input their information in order to be updated with the latest vaccine availability. Scams largely work by trying to create urgency and there’s nothing so urgent as health and safety.
Because of the increase in vaccine-related scams, FinCEN has published guidance about specific ways to file SARs related to these vaccine scams. As a general guideline, in order to effectively respond to and combat fraud schemes, law enforcement and FinCEN require as quickly as possible the full details related to SAR filings, including supporting documentation. Due to the extent of COVID-19 related scams, FinCEN and law enforcement are working even more quickly than normal to combat COVID-19 related scams.
In addition to the general guidance, FinCEN specifically requests that banks reference “FIN-2020-NTC4” in Item 2, when filing vaccine-related SARs. Item 2 is a 50-character field provided for banks to alert FinCEN that the SAR is being filed in response to a specific notice or advisory. FinCEN also requests that “FIN-2020-NTC4” be included in the narrative portion of the SAR to indicate a connection between the suspicious activity being reported and the activities highlighted in notice FIN-2020-NTC4.
Additionally, FinCEN also specifically requests that banks select Item 34 option “z. Other (specify type of suspicious activity in the space provided),” to indicate a connection between the suspicious activity being reported and COVID-19. Banks should include the name of the scam (e.g., vaccine scam) in Item 34(z).
FinCEN further requests that banks detail the reported activity in the SAR narrative. If the activity is suspected of being a scam, banks should provide details (if known) about how the scammers contacted the victim, how the victim provided or attempted to provide payment related to the scammer, and any other pertinent details such as ip-addresses and phone numbers involved in the scam. Likewise, the Justice Department also urges the public to report suspected COVID-19 related scams to the National Center for Disaster Fraud at 1-866-720-5721.