FinCEN issues digital-asset scam-center indicators and reporting instructions

What changed

FinCEN issued FIN-2026-Alert005, supplementing its 2023 digital-asset investment scam alert with scam-center laundering indicators and specific reporting instructions. It requests FIN-2026-SCAMCENTERS in SAR field 2 and the narrative, and Scam Centers under field 34(z), Fraud-Other. An accompanying analysis identifies approximately $12.7 billion in suspected financial activity across 33,904 BSA reports filed from September 8, 2023 through December 31, 2025. That figure is not a measure of proven losses or unique transactions. The alert provides guidance and reminders under existing requirements.

Who it affects

• Banks, broker-dealers, MSBs, and other covered financial institutions encountering suspected scam proceeds
• Advisers assisting clients liquidating investments or transferring assets to purported crypto investments

What is still open

• Whether particular transfers or counterparties are connected to scam activity
• Whether transferred funds can be recovered; reported activity does not establish liability or recoverability

What it means for an advisor

• Review unusual investment liquidations and crypto-transfer requests for scam indicators and escalate concerns through established procedures
• Preserve wallet, transaction, recipient, and communication records for investigation
• Covered SAR filers should incorporate the alert's reporting instructions; advisers should coordinate with relevant custodians without assuming new filing duties