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COVID-19 and Emerging Global Patterns of

Financial Crime



September 4, 2020
Criminal groups around the world are exploiting opportunities for illicit profit during the COVID-19
pandemic. As criminal behaviors shift, so, too, have the illicit financial footprints left behind. As
Congress considers U.S. and international responses to the pandemic, it may also examine the emerging
risks and financial patterns associated with COVID- 19-related criminal activity, including cybercrime.

Risk Context

According to the Financial Action Task Force (FATF), an intergovernmental standards-setting body on
anti-money laundering (AML) and counter-financing of terrorism (CFT), as well as other reporting, the
pandemic has contributed to significant changes in the financial behavior of governments, businesses, and
people in many parts of the world. These changes have also introduced new money laundering and
financial fraud risks. For example:
    *  Economic uncertainty, characterized by high unemployment, business insolvency, and
       disruptions in global trade patterns, has mobilized governments around the world to
       introduce large-scale emergency financial assistance and stimulus programs. Increased
       availability of government funds may challenge authorities to identify fraudulent claims,
       as well as misappropriated and misdirected funds due to corruption.
    *  Voluntary and government-mandated quarantines and stay-at-home orders have reduced
       in-person banking activity and increased online banking and remote transactions. This
       increase in remote banking has challenged financial institutions to comply with
       AML/CFT requirements related to customer identity verification and due diligence.
    *  Financial volatility has driven investors to redistribute assets, resulting in liquidated
       portfolios, large funds transfers, and increases in physical cash holdings, safe haven
       assets (e.g., gold), real estate purchases, and virtual currencies. Major changes in
       financial transaction patterns may obscure criminal activity, particularly when assets are
       converted into less transparent and less traceable forms.
    *  Public health concerns have resulted in the postponement of some on-site inspections of
       financial institutions, delays in some reporting of suspicious financial activity and

                                                                 Congressional Research Service
                                                                   https://crsreports.congress.gov
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