FinCEN Alert FIN-2024-Alert004, issued November 13, 2024, warns that criminals are using generative AI to create deepfake identity documents, images, video, and audio to defeat banks' identity verification, authentication, and due diligence controls. FinCEN reported a rise since 2023 in suspicious activity reports describing deepfake media, typically fraudulent IDs used to open accounts that funnel proceeds of check fraud, credit card fraud, authorized push payment fraud, loan fraud, and unemployment fraud. The alert lists red flags, recommends phishing-resistant multifactor authentication and live verification checks, and asks filers to use the key term FIN-2024-DEEPFAKEFRAUD in SARs.
OFFICIAL TEXT: fincen.gov ↗ · IN FORCE · FINCEN
| Document | FIN-2024-Alert004 (Deepfake Media) — FinCEN Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutions |
| Issued by | Financial Crimes Enforcement Network |
| Type | Guidance |
| Status | In force |
| Published | Nov 13, 2024 |
| Effective | Nov 13, 2024 |
| Applies to | All BSA-covered financial institutions, particularly banks and fintechs performing remote onboarding, identity verification, and authentication |
| Official source | fincen.gov ↗ |
| Use cases | Fraud detection · AML / KYC · Generative & agentic AI · Cybersecurity |
What are the key points of FIN-2024-Alert004 (Deepfake Media)?
- Issued November 13, 2024 as FIN-2024-Alert004 in response to increased SAR filings describing generative-AI deepfakes since 2023
- Defines deepfake media as AI-generated synthetic content (video, images, audio, text) used to impersonate real or fictitious people
- Typologies include altered or wholly synthetic identity documents at account opening, deepfake voice and video in business email compromise, and impersonation in social engineering and elder financial exploitation
- Red flags include inconsistencies between the photo ID and other customer information, images or video that show signs of manipulation, reverse-image-search hits on stock or AI-generated faces, and customer refusal or inability to complete live verification
- Recommends phishing-resistant multifactor authentication, live audio or video verification, and re-verification of high-risk customers
- SAR instructions: reference the alert, use key term FIN-2024-DEEPFAKEFRAUD in field 2 and the narrative, and select fraud-related suspicious activity types
- Reminds institutions of BSA obligations including customer due diligence and the Customer Identification Program
What did FIN-2024-Alert004 (Deepfake Media) change for banks?
This is the first FinCEN document squarely about generative AI. It moved deepfakes from a cybersecurity talking point into a BSA reporting expectation, effectively telling banks that examiners will expect onboarding controls that anticipate AI-generated documents and that SAR narratives should flag suspected deepfake use.
What SAR key term does FinCEN want for deepfake fraud?
FIN-2024-DEEPFAKEFRAUD, entered in SAR field 2 and in the narrative, along with a reference to FIN-2024-Alert004.
Does the deepfake alert require new identity-verification technology?
No. It is an alert, not a rule. It recommends phishing-resistant MFA and live verification checks as ways to reduce exposure, and it reminds institutions of existing CIP and CDD duties.
| Date | Document | Status |
|---|---|---|
| Sep 3, 2026 | FIN-2026-Alert005 (Digital Asset Investment Scam Centers) — FinCEN Alert on Money Laundering Activity Associated with Digital Asset Investment Scam Centers | In force |
| Jul 24, 2026 | FIN-2026-Alert004 (Federal Student Aid Fraud) — FinCEN Alert on Fraud Schemes Targeting Federal Student Aid | In force |
| Apr 10, 2026 | 2026 AML/CFT Program Proposed Rule — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2026) | Proposed |
| Jul 3, 2024 | 2024 AML/CFT Program Proposed Rule (withdrawn) — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2024) | Withdrawn |
| Apr 9, 2021 | 2021 BSA/AML Model Risk Management Statement — Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance | Withdrawn |
| Jan 1, 2021 | Anti-Money Laundering Act of 2020 — Anti-Money Laundering Act of 2020 (Division F of the National Defense Authorization Act for Fiscal Year 2021) | In force |
Which banks' AI programmes does FIN-2024-Alert004 (Deepfake Media) reach?
2 of the 120 largest US banks profiled on this site cite FIN-2024-Alert004 (Deepfake Media) among the documents their AI work answers to.
Which AI tools for banks does FIN-2024-Alert004 (Deepfake Media) apply to?
The buyer's guides in the AI tools directory name FIN-2024-Alert004 (Deepfake Media) among the rules that apply when a bank uses software in this category.
- Fraud detection — Deepfake and synthetic-identity fraud: Feedzai · Featurespace · BioCatch · Sardine · Socure · Alloy · Pindrop · NICE Actimize · Hawk · Unit21 · Zest AI · Provenir · FICO
Follow every document these regulators publish
when one of these regulators moves, the next morning's brief says so · six sourced stories · 7 am ET · free
plus every tracker, bank and agent page update, the morning after · leave any morning