The COVID-19 pandemic has created a perfect storm for money laundering and fraud. As we have blogged, financial institutions subject to the Bank Secrecy Act are facing increased incidents of fraud and must catch and report suspicious or illegal activity while compliance teams face potentially reduced staff and are trying to work remotely. The pandemic also will expose existing incidents of fraud—and investigations and litigation surely will ensue as investors and consumers demand their cash back, only to discover that the money is gone.
But COVID-19 also has created opportunities for non-bank lenders, who can qualify as lenders under the CARES Act’s Payroll Protection Program (PPP) if they enact a sufficient Anti-Money Laundering program. Today, FinCEN issued FAQs regarding AML compliance issues and PPP lending.
We will discuss these issues during a webinar on April 20, 2020, from noon to 1 pm EST. This webinar will explore how financial institutions can remain watchful for fraud during these difficult times and what AML steps non-bank lenders (and banks) must take to qualify as PPP lenders. To register, please click here.