The Headline. The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has joined other federal law enforcement agencies in placing a “whole-of-government” focus on combatting benefits fraud against the federal and state governments. In a March 30, 2026 Healthcare Fraud Advisory (Advisory, FIN-2026-A001), FinCEN urged financial institutions to be vigilant in detecting, preventing, and reporting fraudulent activity targeting governmental healthcare benefits programs, such as Medicare and Medicaid. FinCEN also identified 24 new, healthcare-focused “red flags.” Although the Advisory is directed to financial institutions, non-bank clients in the healthcare sector can derive important guidance from the Advisory’s analysis.
The Background. While certainly not a new federal priority, the Trump Administration has recently upped federal efforts to prevent and punish…
HOW TO SPOT A “RED FLAG” (THE BEHAVIORAL AUDIT)
Keep an eye out for these behavioral shifts in your staff:
Refusal to take leave: Afraid someone will find their “adjustments.”
Unexplained wealth: Buying luxury items that don’t match their known salary.
Working odd hours: Preferring to work alone late at night when no one is watching the system.
“Gatekeeper” behavior: Becoming overly defensive or angry when someone asks to see their records.