COVID-19 has caused a global pandemic, with devastating consequences across nations and industry sectors, but it has not deterred criminals. The FBI and Interpol have noted an increase in risk of COVID-19-related financial crimes and expectations of increased criminal activity. FinCEN and banking regulators have maintained their expectations for Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance programs. Financial institutions are expected to continue to follow a risk-based approach and adhere diligently to their BSA/AML obligations.
Regulators have not lowered expectations, although they have made changes to financial institutions’ requirements to ease compliance obligations in recognition of the operational challenges associated with COVID-19.