The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) on Monday released an advisory directed at financial institutions, urging heightened scrutiny of schemes that exploit government healthcare benefit programs. The guidance targets fraud involving Medicare and Medicaid and is presented as part of a broader effort that supports President Trump’s pledge to combat fraud nationwide.
FinCEN said the advisory follows Treasury Secretary Scott Bessent’s trip to Minnesota earlier this year, during which he outlined steps the department is taking to detect and disrupt fraud involving government benefits. The advisory aims to give banks and other covered institutions a clearer view of how bad actors are abusing healthcare programs and how those abuses can manifest in financial activity.
According to the advisory, fraudsters include organized crime groups and transnational criminal organizations that use a range of tactics to obtain reimbursement from federal and state healthcare benefit programs. FinCEN summarizes money laundering typologies and compiles red-flag indicators designed to help institutions identify suspicious transactions and file appropriate reports.
FinCEN highlighted a notable rise in suspicious-activity reporting tied to healthcare: financial institutions filed 20% more such reports in 2025 than in 2024, following President Trump’s pledge to eliminate fraud nationwide. The agency cautioned, however, that this increase in reporting likely captures only a small portion of the total illicit activity related to healthcare fraud in the United States.
The advisory describes in detail how transnational criminal organizations can exploit federal and state healthcare benefit programs. Schemes include filing false and fraudulent claims for reimbursement for services that are nonexistent, exploitative, substandard, or medically unnecessary. The groups often use a sequence of steps to avoid detection and move proceeds through the financial system.
One tactic outlined by FinCEN involves sending non-resident aliens into the United States to act as straw owners for recently established or purchased healthcare providers or suppliers that are enrolled in federal or state programs. The organizations then illicitly obtain names and identification numbers of beneficiaries enrolled in these programs, using that information to submit fraudulent claims for reimbursement.
FinCEN said the submission of false claims is frequently facilitated through kickbacks and bribes paid to complicit medical professionals. Once reimbursements are issued, payments are routed to bank accounts controlled by shell companies. From those accounts, payouts are laundered through both U.S. and international financial channels by means that include wire transfers, transfers into digital assets, and other methods. The advisory also notes the potential role of complicit insiders at financial institutions in enabling the laundering process.
In a separate but related action on Monday, FinCEN published a proposed rule to establish procedures for its whistleblower program. The proposed rule would set out how whistleblowers can provide information to FinCEN about potential violations and would define eligibility criteria and procedures for adjudicating award applications.
The proposed program specifies that awards to eligible whistleblowers would range from 10% to 30% of monetary penalties resulting from qualifying enforcement actions. Payments to whistleblowers would be funded by penalties collected under the Bank Secrecy Act and the International Emergency Economic Powers Act, and would derive from enforcement actions brought by Treasury and the Department of Justice.
FinCEN’s advisory and the proposed whistleblower rule together signal an increased regulatory focus on financial pathways used to exploit healthcare benefit programs. The guidance provides banks with indicators to improve detection and reporting, while the whistleblower proposal creates a potential financial incentive for individuals to report wrongdoing to authorities.
Note: The advisory covers behavior and schemes described above without asserting comprehensive coverage of all fraud activity. Where details are limited in the advisory, the guidance presents typologies and indicators intended to aid institution-level detection and reporting.