Has Financial Crimes Enforcement Network (FinCen) identified emerging fraudulent transaction trends since the onset of the COVID-19 outbreak?

Yes. On March 16, 2020, FinCEN issued a press release related to the COVID-19 and encourages financial institutions to communicate concerns and remain alert to related illicit financial activity, including the following:

• Imposter Scams: This trend includes bad actors that impersonate government agencies (such as the Centers for Disease Control (CDC)), international organizations (such as the World Health Organization(WHO)), or healthcare organizations in order to solicit donations, steal personal information, or distribute malware.
• Investment Scams: This trend includes promotions that falsely claim that the products or services of a publicly traded company can prevent, detect or cure the coronavirus or COVID-19.
• Product Scams: This trend covers the sale of unapproved or misbranded products that make false health claims pertaining to COVID-19, including by companies that have received public warning letters or statements from the U.S. Federal Trade Commission and the U.S. Food and Drug Administration. The Guidance notes that FinCEN has also received reports relating to the fraudulent marketing of COVID-19 related supplies, including facemasks.
• Insider Trading: FinCEN has also received reports of suspected insider trading related to COVID-19