The Financial Crimes Enforcement Network (FinCEN) is issuing this Notice 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.

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. This Notice also provides specific instructions for filing Suspicious Activity Reports (SARs) regarding such suspicious activity related to COVID-19 vaccines and their distribution.

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.

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