by Elizabeth Davy, Eric J. Kadel, Jr., Sharon Cohen Levin, Shari Leventhal, and John Grein

Background

On March 16, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued guidance (the “Guidance”) encouraging financial institutions to communicate concerns related to the timely filing of reports required under the Bank Secrecy Act (“BSA”) and identifying several patterns of fraudulent transactions that have emerged since the onset of the COVID-19 outbreak.[1] Continue reading →