Pub. 15 2020-2021 Issue 4

WWW.NEBANKERS.ORG 18 COMPLIANCE ALLIANCE D URINGNORMAL TIMES, ITCANBECHALLENGINGFORBANKERS to get their arms around the regulatory requirements surrounding the Bank Secrecy Act (BSA) and anti- money laundering (AML) regulations. So, when you add a global pandemic, such as COVID-19, things can get a little dicey, especially when navigating competing priorities. Fortunately for us, the Federal regulators have been proactive in providing the banking industry with up-to-date compliance guidance (although it is important to note the guidance did not extend the BSA regulatory reporting deadlines) relating to the pandemic. Furthermore, the Financial Crimes Enforcement Network (FinCEN) went as far as creating a webpage devoted The Race is On — Keeping Up With the BSA Steve Manderscheid, Compliance Alliance to coronavirus updates. A brief scan of their webpage includes the following advisories: • AdvisoryonCybercrimeandCyber-EnabledCrimeExploit- ing the Coronavirus Disease 2019 (COVID-19) Pandemic • FinCEN Advisory on Imposter Scams and Money Mule Schemes Related to Coronavirus Disease 2019 (COVID-19) • FinCENAdvisory onMedical ScamsRelated toCOVID-19 • Companion Notice to FinCEN COVID-19 Advisories • PaycheckProtectionProgramFrequentlyAskedQuestions • Updated FinCEN Notice to Financial Institutions Re- garding COVID-19 • FinCEN Notice to Financial Institutions Regarding COVID-19 In these statements, FinCEN encourages financial institu - tions to communicate concerns related to the COVID-19 pan- demic and to remain diligent in detecting related suspicious activity. Hopefully, by now, banks have passed the stage where concerns exist over the potential delays in filing required BSA reports – suspicious activity reports (SARs) and currency trans - action reports (CTRs) – but know that risk was really for many. So that brings us to suspicious activity monitoring and reporting, which is a staple of a safe and sound BSA program. By now, suspicious activity, including illicit fraudulent transac- tions, is not something that is particularly new to us, as we have dealt with many types of fraud – ACH, loan and identity theft fraud – just to name a few. But, since FinCEN has suggested that the banking community “remain alert about malicious or fraudulent transactions similar to those that occur in the wake of natural disasters,” we should take a look at the emerging trends connected to COVID-19: • Imposter Scams – Bad actors attempt to solicit dona - tions, steal personal information, or distributemalware by impersonating government agencies (e.g., Centers for Disease Control and Prevention), international or - ganizations (e.g., World Health Organization (WHO), or health care organizations.