Clifford Chance

FinCEN Advisory Puts Financial Institutions on Notice for Red Flags Indicative of COVID-19 Related Health Care Fraud

February 11, 2021

As the COVID-19 pandemic continues, health care firms and financial institutions are particularly at risk of becoming the subject of pandemic-related enforcement investigations. Because of their role in disbursing government stimulus funds and in processing customer transactions, financial institutions are also expected to identify potential indicators of pandemic-related fraud involving the health insurance and health care industries. On February 2, 2021, the U.S. Department of the Treasury's Financial Crimes Enforcement Network laid out numerous red flags in its Advisory on COVID-19 Health Insurance- and Health Care-Related Fraud and directed financial institutions to be on the lookout for these scenarios.

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