Compliance Briefing — FinCEN outlines BSA expectations during COVID-19 disruptions

Executive briefing: On 16 March 2020, FinCEN advised that Bank Secrecy Act obligations continue during the COVID-19 emergency. The bureau encouraged financial institutions to maintain risk-based AML programs, alert regulators to resource constraints, and file Suspicious Activity Reports on pandemic-related scams.

What changed

• FinCEN confirmed BSA expectations remain in effect but invited institutions to contact their functional regulator and FinCEN about potential COVID-19-related delays.
• The statement flagged emerging fraud typologies—including imposter scams, investment fraud, and product scams—tied to the pandemic.
• Institutions are asked to include the key term "COVID19" in SAR narratives related to the outbreak to aid analysis.

Why it matters

• Maintaining effective AML monitoring is critical as criminals exploit emergency relief programs and market volatility.
• Early communication with regulators about operational impacts can reduce enforcement risk when staffing or technology disruptions affect compliance timelines.
• Explicit SAR tagging improves information sharing with law enforcement for pandemic-related fraud.

Action items for operators

• Review AML staffing coverage and technology capacity under remote-work conditions; document any anticipated filing delays and notify regulators promptly.
• Update fraud detection scenarios to incorporate COVID-19 typologies highlighted by FinCEN and other agencies.
• Train investigators to append "COVID19" in SAR narratives where relevant and to escalate pandemic-themed scams quickly.