Regulatory Alerts2026-03-30
FinCEN Advisory on Health Care Fraud Schemes Targeting Medicare, Medicaid, and Other Federal and State Health Care Benefit Programs
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in coordination with the FBI and HHS-OIG, directs financial institutions to enhance vigilance and reporting of suspicious transactions linked to health care fraud targeting Medicare, Medicaid, and other federal and state benefit programs. The advisory details prevalent fraud typologies, including straw owners, shell companies, and false billing practices like upcoding and phantom billing, alongside associated money laundering methods such as wire transfers, digital asset purchases, and real estate acquisitions. Financial institutions must reference this guidance using the key term “HCF-2026-A001” in Suspicious Activity Report filings, select applicable SAR fields, and immediately notify law enforcement to support the administration’s initiative to combat billions of dollars in illicit government benefit fraud.