Providing yet more proof that anything positive can be twisted into something negative, the Financial Crimes Enforcement Network (“FinCEN”) released a Notice yesterday “to alert financial institutions about the potential for fraud, ransomware attacks, or similar types of criminal activity related to COVID-19 vaccines and their distribution.”  This Notice comes on the heels of several similar advisories issued by FinCEN throughout 2020 regarding medical scams relating to COVID-19; cybercrimes relating to COVID-19; unemployment insurance fraud relating to COVID-19; imposter and money mule schemes relating to COVID-19; and the use of the financial system to facilitate cybercrime and ransomware payments.  The Notice is short, so we simply quote most of it here:

. . . . As of December 28, 2020, the U.S. Food and Drug Administration (FDA) has issued two emergency use authorizations for COVID-19 vaccines in the United States. . . .

COVID-19 vaccine fraud may include the sale of unapproved and illegally marketed vaccines, the sale of counterfeit versions of approved vaccines, and illegal diversion of legitimate vaccines. Already, fraudsters have offered, for a fee, to provide potential victims with the vaccine sooner than permitted under the applicable vaccine distribution plan.

In addition, cybercriminals, including ransomware operators, will continue to exploit the COVID-19 pandemic alongside legitimate efforts to develop, distribute, and administer vaccines. FinCEN is aware of ransomware directly targeting vaccine research, and FinCEN asks financial institutions to stay alert to ransomware targeting vaccine delivery operations as well as the supply chains required to manufacture the vaccines. Financial institutions and their customers should also be alert to phishing schemes luring victims with fraudulent information about COVID-19 vaccines.

The Notice finished by providing specific instructions for filing Suspicious Activity Reports, or SARs, regarding suspicious activity related to COVID-19 vaccines and their distribution.

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