On March 30, 2026, FinCEN issued an Advisory to urge financial institutions to be vigilant in identifying and reporting suspicious transactions potentially related to health care fraud schemes targeting Medicare, Medicaid, and other Federal and state health care benefit programs. The Advisory builds on Treasury’s work to combat the potentially billions of dollars in rampant health care and government benefits fraud in Minnesota and across the country.
According to FinCEN, BSA reporting indicates that health care fraud has increased significantly, with 330% increased from 2020 through 2025. This significant increase in BSA reporting peaked in 2025 with financial institutions filing a record of over 3,800 initial SARs that checked SAR field 34(g) (Healthcare/Public or Private Health Insurance).
HHS, in collaboration with state governments and insurers, administers Health Care Benefit Programs for eligible individuals, including those over 65 and disabled people. Providers must enroll and obtain numbers to submit claims for reimbursement for services rendered to these beneficiaries. The following health care benefit fraud schemes were explained in FinCEN’s Advisory:
Use of straw owners and shell companies to register as health care providers and suppliers;
Filing false and fraudulent claims for non-existent, exploitative, substandard, or unnecessary medical care; and
Obfuscation of fraudulent reimbursements through the U.S. and international financial systems.
FinCEN has also identified the following red flags to help financial institutions detect, prevent, and report suspicious activity connected to health care fraud schemes targeting Health Care Benefit Programs:
A customer with neither legal permanent residence in the United States nor significant experience in the health care industry (e.g., based on the customer’s stated occupation) tries to open a bank account as the owner or employee of a recently established or purchased health care provider or supplier registered with a Health Care Benefit Program.
A customer is a health care provider or supplier registered with a Health Care Benefit Program that has beneficial owners with prior health care or government benefits fraud convictions.
A customer is the nominal or beneficial owner of a health care provider or supplier registered with a Health Care Benefit Program and has familial or business affiliations with individuals with health care or government benefits fraud convictions.
A customer is a health care provider or supplier registered with a Health Care Benefit Program, and the account is accessed through an Internet Protocol (IP) address or Device ID that is linked to multiple accounts at the financial institution or other financial institutions or connected to foreign jurisdictions.
A customer is a health care provider or supplier registered with a Health Care Benefit Program and has nominal and beneficial owners listed on the account who also appear on bank accounts for other separate and distinct health care providers or suppliers.
A customer is a recently established or purchased health care provider or supplier registered with a Health Care Benefit Program, and there are changes in the individuals listed as beneficiaries of the corporate account without a change to the name or Tax Identification Number on the account.
A customer that is a recently established or purchased health care provider or supplier receives a significant amount of reimbursements from a Health Care Benefit Program or commercial insurers and then immediately transfers those funds to other recently established companies with the same nominal or beneficial owners, little to no online presence, and other indicators of illicit shell company activity.
A customer is a recently established health care provider or supplier that receives a significant number of reimbursements from a Health Care Benefit Program or commercial insurers soon after starting operations.
A customer is a health care provider or supplier registered with a Health Care Benefit Program that is receiving a significant increase in reimbursements soon after a change in beneficial ownership.
A customer is a health care provider or supplier that suddenly has a significant increase in reimbursements from Health Care Benefit Programs or commercial insurers.
A customer is a recently established or purchased health care provider or supplier registered with Health Care Benefit Programs or commercial insurers that receives a significant amount of reimbursements inconsistent with the customer’s profile (e.g., receiving a significant amount of payments from Medicare Part A and Part B MACs for reimbursements beyond the expected activity of other similar health care providers or suppliers).
A customer is a health care provider or supplier that receives significant volumes of reimbursements from a Health Care Benefit Program or commercial insurers but has little to no legitimate business expenses associated with the provision of health care goods and services (e.g., receiving reimbursements from DME MACs but little to no purchases of DME).
A customer is a health care provider or supplier that receives a significant volume of reimbursements from a single Health Care Benefit Program as opposed to other customers that receive reimbursements from multiple Health Care Benefit Programs (e.g., a customer is receiving a significant amount of reimbursements from one MAC for only one type of health care good or service such as DME).
A customer is a health care provider or supplier with a significant amount of transactional activity consisting of “consulting fees,” “marketing fees,” and other nondescriptive, repetitive invoices.
A customer is a health care provider or supplier that receives a significant volume of reimbursements from a Health Care Benefit Program and transfers the funds to another company registered to a residential address.
A customer is a health care provider or supplier that has outgoing transactions to, or expenditures related to, companies that have no apparent related nexus to the health care industry. This could include residential real estate and luxury goods such as art or jewelry.
A customer is a health care provider or supplier with consistently low to moderate billing for a year or more and then suddenly begins to file a large number of claims (i.e., spike billing).
A customer is a health care provider or supplier with a pattern of making significant cash withdrawals for no readily apparent business reason.
A customer is a health care provider or supplier with a significant increase in cash withdrawals correlating to a significant increase in billings (i.e., customer is potentially paying kickbacks).
A customer is a health care provider or supplier that is transferring a significant volume of funds to individuals via high-value checks.
Without credible explanation, a customer routinely cashes high-value checks drawn from accounts associated with a health care provider or supplier.
A customer that is a health care provider or supplier, or the customer’s employee, engages in behavior suggesting efforts to evade the Currency Transaction Report (CTR) reporting requirement (e.g., alters or cancels a transaction when advised a CTR would be filed or engages in structuring with multiple cash transactions for under $10,000), as well as avoid recordkeeping requirements.
A customer is a recently established or purchased health care provider or supplier registered with a Health Care Benefit Program that sends a significant amount of wire transfers to individuals and companies located in foreign jurisdictions.
A customer is a health care provider or supplier registered with a Health Care Benefit Program that sends money transfers to VASPs, brokerage accounts, and online betting platforms for no seemingly legitimate business reason.
FinCEN’s press release can be found here.
The full Advisory can be found here.