FinCEN Identifies $17.5 Billion in Suspicious Activity Potentially Linked to Health Care Fraud

The US Financial Crimes Enforcement Network (FinCEN) has identified approximately $17.5 billion in suspicious financial activity potentially linked to health care fraud in a review of Bank Secrecy Act reports filed by financial institutions between March 1, 2025 and February 28, 2026.

The findings were published in a Financial Trend Analysis examining patterns identified in 5,702 Bank Secrecy Act reports. The reports concerned suspected health care fraud and suspicious receipt of government payments associated with health care-related terms. The $17.5 billion figure includes both attempted and completed transactions and does not represent a confirmed calculation of criminal proceeds or actual losses.

FinCEN's analysis was conducted under Section 6206 of the Anti-Money Laundering Act of 2020, which requires FinCEN to periodically publish information derived from Bank Secrecy Act data concerning financial crime threats, patterns and trends. The review examined reports submitted by financial institutions during the 12-month period ending February 28, 2026.

The 5,702 reports were submitted by 471 financial institutions. Depository institutions accounted for the majority of the reporting, filing 5,080 reports, or approximately 89% of the dataset. These reports represented approximately $15.2 billion of the reported suspicious activity, equivalent to nearly 87% of the total amount identified in the analysis.

The individual reports covered a wide range of amounts. FinCEN's analysis found an average reported amount of approximately $3.3 million and a median reported amount of approximately $600,000. The dataset contained an average of 475 reports per month during the review period.

The analysis identified health care providers and businesses as central participants in many of the transactions examined. Home health care businesses were the provider type most frequently identified outside the Puerto Rico eligibility subset included in the dataset.

FinCEN found that suspected fraudulent health care payments could move through accounts associated with legitimate-looking health care providers before being transferred to other businesses, individuals or accounts. The transactions identified in the reports included transfers to personal accounts, related companies, shell entities, real estate transactions, digital assets and recipients located outside the United States.

The analysis examined financial activity associated with federal and state health care benefit programmes. FinCEN had previously issued an advisory in March 2026 addressing schemes targeting Medicare, Medicaid and other federal and state health care benefit programmes. That advisory described money laundering typologies and indicators associated with health care fraud and reminded financial institutions of their reporting obligations under the Bank Secrecy Act.

The March advisory identified schemes involving fraudulent billing, false claims, identity-related fraud and other methods used to obtain payments from health care benefit programmes. The subsequent Financial Trend Analysis uses Bank Secrecy Act reporting data to examine how suspected proceeds associated with these activities appeared in the financial system.

FinCEN's latest analysis also identified geographic information associated with the subjects named in the reports. Most of the subjects were based in the United States. Approximately 1.5% of the roughly 13,000 subject addresses identified in the reports were foreign addresses. The dataset contained an average of 2.3 addresses for each BSA report.

At state level, California, Florida and Minnesota were among the jurisdictions with significant numbers of subject addresses. FinCEN identified 692 US counties and 75 Puerto Rican localities in the dataset. Los Angeles County in California, Hennepin County in Minnesota and Miami-Dade County in Florida were the three counties appearing most frequently in the reports.

Los Angeles County was associated with 777 reports, Hennepin County with 300 reports and Miami-Dade County with 247 reports. These figures relate to the number of reports in which subject addresses were associated with the respective counties and do not represent confirmed cases of fraud in those locations.

The reports examined by FinCEN contained information concerning transactions involving health care providers, patients, businesses and other parties. Financial institutions identified suspicious activity based on information available to them through account activity and other financial data.

The analysis also illustrates the distinction between financial intelligence and confirmed criminal conduct. The $17.5 billion identified by FinCEN represents suspicious activity reported under the Bank Secrecy Act. It includes attempted transactions as well as completed transactions, and the reported amounts can include continuing activity and other transactions that may overlap. The figure therefore should not be treated as the amount of confirmed health care fraud losses.

FinCEN stated that the dataset was developed by identifying BSA reports that either selected health care fraud as a suspicious activity category or contained indications of suspicious receipt of government payments together with relevant health care terminology. The agency then used automated and manual review to remove false positives and validate the dataset.

The reporting institutions included banks and other depository institutions as well as other financial businesses. Two of the largest banks by assets accounted for approximately 29% of all filings in the dataset, while one institution submitted approximately 1,100 reports.

The financial activity described in the reports included transfers between accounts connected to health care providers and other entities. Some reports identified transactions involving businesses connected to the providers, while others identified movement of funds to individuals or entities with no apparent health care-related purpose based on the information available to the reporting institution.

The analysis also identified the use of funds for personal expenditure and purchases of assets. Reported transactions included spending on real estate and other high-value assets, transfers between related entities and movement of funds into digital assets.

In some cases, reported activity involved international recipients or accounts outside the United States. Foreign addresses accounted for approximately 1.5% of the subject addresses identified in the dataset, although the reports could contain transactions involving foreign parties without the subjects themselves being located outside the United States.

FinCEN's review follows increased federal attention to fraud involving government benefit programmes. In March 2026, the agency issued its health care fraud advisory in cooperation with federal law enforcement agencies, including the FBI and the Department of Health and Human Services Office of Inspector General.

The March advisory stated that FinCEN's information was based on analysis of Bank Secrecy Act data, open-source reporting and information provided by law enforcement partners. It also described financial indicators associated with health care fraud schemes and encouraged financial institutions to report suspicious activity and notify law enforcement concerning fraud targeting health care benefit programmes.

The September 2026 Financial Trend Analysis provides additional information based specifically on BSA reporting during the subsequent review period. It identifies the volume and value of suspicious transactions reported by financial institutions and describes patterns in the movement of funds associated with suspected health care fraud.

The $17.5 billion identified in the analysis represents the combined value of approximately 5,702 suspicious activity reports filed during the year-long review period. The reports originated from 471 financial institutions and included transactions that were attempted as well as those that were completed.

FinCEN's findings do not establish that all of the transactions in the dataset represented fraud or criminal proceeds. The agency's analysis is based on suspicious activity reports submitted by financial institutions, and the reported transaction amounts may include legitimate activity associated with individuals or businesses that were the subjects of the reports.

The publication nevertheless provides a detailed account of financial activity reported in connection with suspected health care fraud during the period from March 2025 through February 2026. It identifies the institutions submitting the reports, the geographic locations associated with subjects, the types of businesses appearing in the reports and the movement of funds identified by financial institutions.

FinCEN's latest findings form part of its continuing publication of financial intelligence derived from Bank Secrecy Act reporting. The agency has stated that the information is intended to provide information on financial crime patterns and trends and to support the use of BSA data by government agencies, financial institutions and other relevant stakeholders.

The latest analysis records approximately $17.5 billion in suspicious activity potentially linked to health care fraud, across 5,702 BSA reports filed during the 12-month review period. The findings cover both attempted and completed transactions and identify financial activity involving health care providers, related businesses, personal accounts, assets, digital assets and foreign recipients.

By fLEXI tEAM