The Financial Crimes Enforcement Network (FinCEN) recently issued an advisory to banks that outlined fourteen red flag indicators to be on the lookout for (and report) related to pandemic related economic relief payments. Entitled “Advisory on Financial Crimes Targeting COVID-19 Economic Impact Payments,” FinCEN issued the advisory based on its “analysis of COVID-19-related information obtained from Bank Secrecy Act (BSA) data, public reporting, and law enforcement partners.”

The types of fraud that have been detected include criminals sending fraudulent checks to potential victims, and then requesting personal information in order to cash them; altering checks and depositing them via ATMs or mobile devices; counterfeit checks; theft of economic relief payments from the U.S. mail; phishing schemes using economic relief as the subject matter; and seizure of economic relief payments inappropriately (wage garnishment or debt collection).

FinCEN outlines fourteen financial red flag indicators that include “fraudulent, altered, counterfeit, or stolen EIP checks, Automated Clearing House deposits and prepaid debit cards.”  The indicators can be accessed here.

Photo of Linn Foster Freedman Linn Foster Freedman

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her…

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law.  Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.