RegAlert2025-03-31 | FIN-2025-Alert001Added · Updated
FinCEN Alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations
FinCEN requests that financial institutions reference alert FIN-2025-Alert001 in Suspicious Activity Report field 2 and field 36(z) using the key terms "FIN-2025-BULKCASH" and "BULKCASH". The alert outlines typologies where Mexico-based transnational criminal organizations smuggle bulk cash into Mexico and repatriate it to the U.S. via armored car services and air transport to launder illicit proceeds. It provides specific red flag indicators for depository institutions and armored car services to detect these cross-border movements and reminds institutions of their reporting obligations under the Bank Secrecy Act.
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- See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t).
- See 31 U.S.C. § 5332.
- According to the U.S. Department of Homeland Security (DHS), TCOs are increasingly augmenting bulk currency
smuggling with the use of alternate value platforms, such as stored value cards, money orders, cryptocurrency, wire transfers, funnel accounts, and trade-based money laundering in response to financial regulations and law enforcement efforts to identify money laundering networks. See DHS “Statement of Acting Executive Associate Director Anthony Salisbury” (Mar. 8, 2023), at p. 5. - Since 2015, Treasury’s National Money Laundering Risk Assessment has identified the U.S. southwest border as an
area of significant risk for bulk cash smuggling and money laundering operations conducted by TCOs and drug trafficking organizations. See U.S. Department of the Treasury, “2024 National Money Laundering Risk Assessment” (“2024 NMLRA”) (Feb. 2024), at pp. 43-44. In March 2025, FinCEN issued a Geographic Targeting Order (GTO) to further combat the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border of the United States. See FinCEN, “FinCEN Issues Southwest Border Geographic Targeting Order” (Mar. 11, 2025). - While there has been a longstanding repatriation of cash surpluses via ACSs from Mexico-based financial institutions
to U.S.-based financial institutions, the TCOs’ operations described in this Alert are separate from, but are intended to capitalize on, this traditional cross-border movement of cash. FIN-2025-Alert001 March 31, 2025 FinCEN Alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations The U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) is issuing this Alert to financial institutions,1 urging them to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash2 from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by Mexico-based transnational criminal organizations (TCOs). This Alert highlights one of several typologies that TCOs use to launder illicit proceeds generated in the United States through the cross-border movement of cash.3
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Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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