FIN-2020-A005: Advisory on cybercrime exploiting COVID-19 (CVC mentions)

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Fincen

2020-07-30

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

FIN-2020-A005                                                        July 30, 2020

        Advisory on Cybercrime and Cyber-Enabled Crime
             Exploiting the Coronavirus Disease 2019
                      (COVID-19) Pandemic
Detecting, preventing, and reporting illicit transactions and cyber activity will
help protect legitimate relief efforts for the COVID-19 pandemic and help protect
financial institutions and their customers against malicious cybercriminals and
nation-state actors.

This Advisory should be shared with:                          Introduction
• Chief Executive Officers               The Financial Crimes Enforcement Network (FinCEN)
• Chief Operating Officers               is issuing this advisory to alert financial institutions to
                                         potential indicators of cybercrime and cyber-enabled
• Chief Compliance Officers
                                         crime observed during the COVID-19 pandemic. Many
• Chief Risk Officers
                                         illicit actors are engaged in fraudulent schemes that
• AML/BSA Departments                    exploit vulnerabilities created by the pandemic. This
• Legal Departments                      advisory contains descriptions of COVID-19-related
• Cyber and Security Departments         malicious cyber activity and scams, associated financial
                                         red flag indicators, and information on reporting
• Customer Service Agents
                                         suspicious activity.
• Bank Tellers
                                         This advisory is intended to aid financial institutions in
                                         detecting, preventing, and reporting potential COVID-
SAR Filing Request:                      19-related criminal activity. This advisory is based on
FinCEN requests financial institutions   FinCEN’s analysis of COVID-19-related information
reference this advisory in SAR field     obtained from Bank Secrecy Act (BSA) data, open source
2 (Filing Institution Note to FinCEN)    reporting, and law enforcement partners. FinCEN
and the narrative by including the       will continue issuing COVID-19-related information
following key term: “COVID19-            to financial institutions to help enhance their efforts to
CYBER FIN-2020-A005” and                 detect, prevent, and report suspected illicit activity on its
select SAR field 42 (Cyber Event).       website at https://www.fincen.gov/coronavirus, which
Additional guidance on filing            also contains information on how to register to receive
SARs appears near the end of this        FinCEN Updates.
advisory.

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     Financial Red Flag Indicators of Cybercrime and Cyber-Enabled
                        Crime Exploiting COVID-19
This advisory addresses the primary means by which cybercriminals and malicious state actors
are increasingly exploiting the COVID-19 pandemic in cyber-enabled crime through malware and
phishing schemes, extortion, business email compromise (BEC) fraud, and exploitation of remote
applications, especially against financial and healthcare systems.1

FinCEN has identified the following red flag indicators of COVID-19 cyber-enabled crimes2 to assist
financial institutions in detecting, preventing, and reporting suspicious transactions associated with
the COVID-19 pandemic. As no single financial red flag indicator is necessarily indicative of illicit
or suspicious activity, financial institutions should consider additional contextual information and
the surrounding facts and circumstances, such as a customer’s historical financial activity, whether
the transactions are in line with prevailing business practices, and whether the customer exhibits
multiple indicators, before determining if a transaction is suspicious or otherwise indicative
of potential fraudulent COVID-19-related activities. In line with their risk-based approach to
compliance with the BSA, financial institutions are also encouraged to perform additional inquiries
and investigations where appropriate. Additionally, some of the financial red flag indicators
outlined below may apply to multiple COVID-19-related fraudulent activities. Given that many
scammers may be directly targeting customers, financial institutions should remain on the alert for
potential suspicious activities involving their customers.

            Targeting and Exploitation of Remote Platforms and Processes
The significant migration toward remote access in the pandemic environment presents
opportunities for criminals to exploit financial institutions’ remote systems and customer-facing
processes. Cybercriminals and malicious state actors are targeting vulnerabilities in remote

1.   See Department of Justice (DOJ) Press Release, “Department of Justice Announces Disruption of Hundreds of Online
     COVID-19 Related Scams,” (April 22, 2020); the United Kingdom (U.K.) National Cyber Security Centre (NCSC)
     Press Release, “Public Urged to Flag Coronavirus Related Email Scams as Online Security Campaign Launches,”
     (April 21, 2020); Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA)
     Notification, “Defending Against COVID-19 Cyber Scams,” (March 6, 2020); Europol Report, “Pandemic Profiteering:
     How Criminals Exploit the COVID-19 Crisis,” (March 27, 2020); DHS CISA and Federal Bureau of Investigation (FBI)
     Public Service Announcement, “People’s Republic of China (PRC) Targeting of COVID-19 Research Organizations,”
     (May 13, 2020); FBI’s Internet Crime Complaint Center (IC3) Public Service Announcement, “Increased Use of Mobile
     Banking Apps Could Lead to Exploitation,” (June 10, 2020); and DHS CISA, National Security Agency, NCSC, and
     Canada Communications Security Establishment Joint Advisory, “APT29 Targets COVID-19 Vaccine Development,”
     (July 16, 2020).
2.   For the purpose of this advisory, cyber-enabled crime refers to illegal activities (e.g., fraud, identity theft, etc.)
     carried out or facilitated by electronic systems and devices, such as networks and computers. See FinCEN Advisory,
     FIN-2016-A005, “Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime,” (October 25, 2016).

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applications and virtual environments to steal sensitive information, compromise financial
activity, and disrupt business operations.3 Remote identity processes4 also face significant risks,
which may include:

• Digital Manipulation of Identity Documentation: Criminals often seek to undermine online identity
  verification processes through the use of fraudulent identity documents, which can be created
  by manipulating digital images of legitimate government-issued identity documents to alter the
  information and/or photos displayed.5

• Leveraging Compromised Credentials Across Accounts: Cybercriminals commonly undermine
  weak authentication processes in attempted account takeovers via methods such as credential
  stuffing attacks. In these attacks, cybercriminals generally use lists of stolen account credentials
  (typically usernames or email addresses, and associated passwords) to conduct automated login
  attempts to gain unauthorized access to victim accounts.

Financial red flag indicators of this sort of activity may include:6

       Pictures in identity documentation, especially areas around faces, are blurry or low resolution, or
       have aberrations. Pictures in identity documentation or other images of persons in remote identity
       verification show visual signs indicating possible image manipulation (e.g., incongruences in
       coloration near the edge of the face, or double edges or lines on delineated facial features).

3.   For information related to publicly disclosed cybersecurity vulnerabilities and exposures, see U.S. Department of
     Commerce, National Institute for Standards and Technology (NIST), “National Vulnerability Database;” MITRE,
     “Common Vulnerabilities and Exposures: CVE List Home;” and FBI IC3 Public Service Announcements, “Cyber
     Actors Take Advantage of COVID-19 Pandemic to Exploit Increased Use of Virtual Environments,” (April 1, 2020)
     and “Increased Use of Mobile Banking Apps Could Lead to Exploitation,” (June 10, 2020). See also FinCEN Director
     Kenneth A. Blanco’s, prepared remarks delivered at the Consensus Blockchain Conference, “Consensus Blockchain
     Conference (Virtual),” (May 13, 2020).
4.   For the purposes of this advisory, “remote identity processes” include remote processes for customer onboarding and
     identity verification, as well as authentication of customers for account access purposes. For more information on
     digital identity standards, see NIST, “Digital Identity Guidelines,” (December 1, 2017), and the Financial Action Task
     Force (FATF), “Guidance on Digital Identity,” (March 6, 2020).
5.   Criminals exploiting identity verification processes will typically use either information associated with a real
     individual’s identity (i.e., identity theft) or create a new fabricated identity that usually consists of a real identifier,
     such as a social security number or driver’s license number, with other fake information (i.e., synthetic identity fraud).
     For more information on example typologies and financial red flag indicators involving identity theft and identity
     fraud, see FinCEN Report, “Identity Theft: Trends, Patterns, and Typologies Reported in Suspicious Activity Reports,”
     (October 2010).
6.   Id. See also Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation, 16 CFR Part 681, app. A.
7.   Images in identity verification other than identity documentation may include pictures or video of the customer (e.g.,
     “selfie” images) taken as part of the financial institution’s onboarding process.

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                                  Phishing, Malware, and Extortion
FinCEN and U.S. law enforcement have observed significant increases in broad-based and
targeted phishing campaigns that are attempting to lure companies, especially healthcare and
pharmaceutical providers, with offers of COVID-19 information and supplies.8 Phishing scams
target individuals with communications appearing to come from legitimate sources to collect
victims’ personal and financial data and potentially infect their devices by convincing the target to
download malicious programs.9 Cybercriminals usually send these phishing communications by
email but may also use phone calls or text messages.

In these new schemes, phishing scammers will often reference COVID-19 themes, such as payments
related to the Coronavirus Aid, Relief, and Economic Security (CARES) Act,10 in the subjects and
bodies of emails. Some phishing emails lure victims by advertising ways to make money, such as
through investing in convertible virtual currencies (CVCs) or via domain names that mimic names
of organizations, including those that provide or enable teleworking capabilities.11 Cybercriminals

8.   The U.S. Secret Service (USSS) and DHS CISA have noted an increase in malware, phishing, and extortion campaigns
     related to COVID-19. See USSS Press Release, “Secret Service Issues COVID-19 (Coronavirus) Phishing Alert,” (March
     9, 2020).
9.   See DHS CISA and U.K. NCSC Joint Alert (AA20-099A), “COVID-19 Exploited by Malicious Cyber Actors,” (April 8,
     2020); and DHS, “Common Scams: Know How to Spot a Fake.”
10. Pub. L. 116–136, 116th Congress (2020).
11. Since January 2020, tens of thousands of new domains have been registered with terms related to COVID-19 and/or
    disaster and healthcare response efforts (e.g., “quarantine,” “vaccine,” and “CDC”), many including or mimicking
    names of companies that provide or enable teleworking capabilities. U.S. law enforcement agencies have disrupted
    hundreds of malicious domains used to exploit the pandemic. See FinCEN Advisory, FIN-2020-A003, “Advisory on
    Imposter Scams and Money Mule Schemes Related to Coronavirus Disease 2019 (COVID-19),” (July 7, 2020). See
    also, FBI Press Release, “FBI Expects a Rise in Scams Involving Cryptocurrency Related to the COVID-19 Pandemic,”
    (April 13, 2020).

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are also distributing malware,12 including ransomware, through phishing emails, malicious
websites and downloads, domain name system (DNS) hijacking or spoofing attacks, and fraudulent
mobile applications. These techniques can be applied in broader campaigns involving social
media, such as the recent exploit targeting Twitter and prominent users of the platform.13 Financial
institutions dealing in CVC should be especially alert to the potential use of their institutions to
launder proceeds affiliated with cybercrime, illicit darknet marketplace activity, and other CVC-
related schemes and take appropriate risk mitigating steps consistent with their BSA obligations.

FinCEN assesses that instances of extortion will also continue to grow in the wake of the COVID-19
pandemic. So far in 2020, FinCEN has received numerous suspicious activity reports (SARs)
involving ransomware14 targeting medical centers and municipalities. Much of this ransomware
was delivered by exploiting the COVID-19 lures described above. We expect criminals to continue
targeting entities that are vulnerable due to their involvement in pandemic response, such as
researchers working on medical treatments or manufacturers of personal protective equipment.
In other instances of extortion, criminals are threatening to expose victims and their families to
COVID-19 if they do not pay the extortion fee. In almost all cases, criminals require ransomware-
related extortion payments to be made in CVC.15

Financial red flag indicators of this sort of activity may include the following:

      Information technology enterprise activity related to transaction processes or information is
      connected to cyber indicators that have been associated with possible illicit activity. Malicious
      cyber activity may be evident in system log files, network traffic, or file information.

12. Malware can enable criminals to access compromised computers and computer systems to steal credentials, exfiltrate
    sensitive information through mechanisms like screenshots or keylogging, alter account information, and conduct
    fraudulent transactions.
13. See FinCEN Alert, FIN-2020-Alert001, “FinCEN Alerts Financial Institutions to Convertible Virtual Currency Scam
    Involving Twitter,” (July 16, 2020).
14. Ransomware, a specific type of malware, typically encrypts data on systems in the interest of extorting ransom
    payment from victims in exchange for decrypting the information and giving victims access to their systems again.
15. Financial institutions dealing in CVC should be especially alert to the laundering of proceeds affiliated with
    cybercrime, illicit darknet marketplace activity, and other CVC-related schemes. See FinCEN Advisory, FIN-2019-003,
    “Advisory on Illicit Activity Involving Convertible Virtual Currency,” (May 9, 2019).
16. Because cyber indicators are helpful red flag indicators that financial institutions can use to identify related suspicious
    financial activity, FinCEN, DHS CISA, and the U.S. Department of the Treasury’s Office of Cybersecurity and
    Critical Infrastructure Protection (OCCIP) offer a broad range of helpful cyber indicator resources, including, but not
    limited to: FinCEN’s Cyber Indicator Lists (CILs), shared through the FinCEN Secure Information Sharing System;
    OCCIP’s CILs and circulars, available upon request; and DHS CISA’s cyber analytic products and services, including
    a comprehensive list of COVID-19-related indicators of compromise in CSV or STIX-formatted XML formats, the
    Cyber Information Sharing and Collaboration Program (CISCP), and the Automated Indicator Sharing (AIS) program.
    Public-private and industry partnerships, such as the Financial Services Information Sharing and Analysis Center,
    and open source and commercial cyber threat feeds can also be useful resources.

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                          Business Email Compromise (BEC) Schemes
Cybercriminals have increasingly exploited the COVID-19 pandemic by using BEC schemes,
particularly targeting municipalities and the healthcare industry supply chain. A common
BEC scheme involves criminals convincing companies to redirect payments to new accounts,
while claiming the modification is due to pandemic-related changes in business operations.
BEC criminals often use spoofed or compromised email accounts to communicate these urgent,
last-minute payment changes. In the COVID-19 environment, criminals insert themselves into
communications by impersonating a critical player in a business relationship or transaction,
typically posing as providers of healthcare supplies, to intercept or fraudulently induce a payment
for critically needed supplies.17

Financial red flag indicators of this sort of activity may include the following:18

17. See FBI Press Release, “FBI Anticipates Rise in Business Email Compromise Schemes Related to the COVID-19
    Pandemic,” (April 6, 2020). See also Europol Press Release, “Corona Crimes: Suspect Behind €6 Million Face Masks
    and Hand Sanitisers Scam Arrested Thanks to International Police Cooperation,” (April 6, 2020).
18. For general BEC-scheme financial red flag indicators, see FinCEN Advisories, FIN-2016-A003, “Advisory to Financial
    Institutions on E-mail Compromise Fraud Schemes,” (September 6, 2016), and FIN-2019-A005, “Updated Advisory on
    Email Compromise Fraud Schemes Targeting Vulnerable Business Processes,” (July 16, 2019).

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                  Information on Reporting Suspicious Activity

                      Suspicious Activity Report (SAR) Filing Instructions
  SAR reporting, in conjunction with effective implementation of due diligence requirements by
  financial institutions, is crucial to identifying and stopping financial crimes, including those
  related to the COVID-19 pandemic. Financial institutions should provide all pertinent available
  information in the SAR and narrative. Adherence to the filing instructions below will improve
  FinCEN and law enforcement’s ability to effectively identify and pull actionable SARs and
  information from the FinCEN Query system to support COVID-19-related cases.

  • FinCEN requests that financial institutions reference this advisory by including the key term
    “COVID19-CYBER FIN-2020-A005” in SAR field 2 (Filing Institution Note to FinCEN) and
    the narrative to indicate a connection between the suspicious activity being reported and the
    activities highlighted in this advisory.

  • Financial institutions that suspect fraudulent COVID-19-related activity should mark all
    appropriate check boxes on the SAR form to indicate a connection between COVID-19 and
    the suspicious activity being reported. For example, if the activity includes a COVID-19-
    related account takeover involving an ACH transfer, financial institutions can select SAR
    field 38a and 38z, and note in the “other” box, “COVID-19 account takeover fraud – ACH.”19

  • Financial institutions should also include any relevant technical cyber indicators related to
    cyber events and associated transactions reported in a SAR within the available structured
    cyber event indicator fields. For example, for a COVID-19-related cyber event against a
    financial institution, financial institutions can select SAR fields 42a and 42z (noting in the

19. For additional guidance on identifying account takeover activity and related SAR filing instructions, see FinCEN
    Advisory, FIN-2011-A016, “Account Takeover Activity,” (December 19, 2011).

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    “other” box the COVID-19-related cyber event), and SAR fields 44(a)-(j), (z), including
    email or CVC wallet addresses, malicious domains or URLs, and any other known cyber
    event indicators.

 • For cyber-enabled crime involving fraud driven by COVID-19, financial institutions should
   select SAR field 34z (Fraud – other) as the associated suspicious activity type. Additionally,
   financial institutions should include the type of cybercrime or scheme as a keyword (e.g.,
   “COVID 19 BEC Fraud,” “EAC fraud,” or “BEC data theft”) in SAR field 34(z).

 • Please refer to FinCEN’s May 18, 2020 Notice Related to the Coronavirus Disease 2019,
   which contains information regarding reporting COVID-19-related crime and FinCEN’s
   Rapid Response Program, and reminds financial institutions of certain BSA obligations.

                                  For Further Information
Financial institutions should send questions or comments regarding the contents of this advisory to
the FinCEN Regulatory Support Section at [email protected].

         The mission of the Financial Crimes Enforcement Network is to safeguard
         the financial system from illicit use, combat money laundering and its
         related crimes including terrorism, and promote national security through
         the strategic use of financial authorities and the collection, analysis, and
         dissemination of financial intelligence.

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